ML20133G760
| ML20133G760 | |
| Person / Time | |
|---|---|
| Issue date: | 07/30/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8508090065 | |
| Download: ML20133G760 (118) | |
Text
I ORIGINAt
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' UNITED STATES OF AMERICA 7
NUCLEAR REGULATORY COMMISSION In the matter of:
COMMISSION MEETING Continuation of 5/15 Briefing on Proposed Revision of Part 20 (SECY-85-147)
(Public Meeting)
Docket No.
[
h i
l Location: Washington, D. C.
Date: Tuesday, July 30, 1985 Pages: 1 - 88 l
l b508090065850730 PDR 10CFR PT9.7 PDR ANN RILEY & ASSOCIATES Court Reporters l "
1625 I St., N.W.
Suite 921 Washington, D.C.
20006 l
(202) 293-3950 L
a-1 D I SC L A I M EP 2
.3 4
5 6
This is an unofficial transcript of 2 meeting of the
- Tuesday, 7
United States Nuclear Regulatory Commission held on 3
July 30, 1985 in the Commission's office at 1717 H Street, 9
N.W.,
Washington, D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes.
As provided by 10 CFR 9.108, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of epinion in this transcript 17 do not necessarily reflect final determination or beliefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except a f.
the Commission may 21 authorire.
22 23 24 l
25 h
1 w
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 CONTINUATION OF 5/15 BRIEFING ON PROPOSED REVISION 5
OF PART 20 (SECY-85-147) 6 7
PUBLIC MEETING 8
Room 1130 9
1717 H Street, Northwest 10 Washington, D.C.
11 Tuesday, July 30, 1985 12 The commission met, pursuant to notice, at 10:05 13 o' clock, a.m.
14 COMMISSIONERS PRESENT:
15 NUNZIO J.
PALLADINO, Chairman of the Commission 16 FREDERICK M.
BERNTHAL, Commissioner 17 p
THOMAS M.
ROBERTS, Commissioner 18 LANDO W.
- ZECH, JR.,
Cc missioner 19 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
20 M.
MALSCH 21 H.
DENTON 22 K.
GOLLER 23 W.
DIRCKS 24 R.
CUNNINGHAM 25 AUDIENCE SPEAKERS:
5 e-2 1
R.
ALEXANDER 2
G.
CUNNINGHAM 3
D.
COOL 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
a -
)
l 3
(10:05 a.m.)
3 CHAIRMAN PALLADINO:
Good morning, ladies and 1
4 gentlemen.
With us today are members of the NRC staff to 5
discuss SECY-85-147, proposed revision to 10 CFR Part 20, 6
standards for protection against radiation.
7 On May 15th, 1985 the Commission met with the staff 8
to discuss this subject for the first time.
Subsequently the 9
Commission scheduled today's briefing to further discuss three 10
.of the most salient points covered by the proposed Part 20 11 revisions.
Those are:
protection of embryo / fetus, de minimus 12 exposure levels and reporting the work'er doses.
13 The topics for today's staff presentation are 14 complex and interrelated and certain aspects of each are 15 highly controversial I'm hopeful that the one and-a-half 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> allotted for today's meeting will be sufficient for 17 discussion of these and other issues that may arise during the 18 discussion.
19 SECY-85-147 identifies the issues and describes 20 various alternatives.
I believe that the staff has made great 21 efforts to reconcile differences on various points of view on 22 the controversial issues involved.
23 I believe it is important in today's meeting for the 24 Commission to provide reaction to the staff regarding issuance 25 of the proposed rulemaking for comment Therefore, I suggest
4 1
that we allow time at the end of today's meeting to discuss 2
Commissioner thoughts on readiness for publication of proposed 3
rule in the Federal Register for 120-day comment period.
4 I had hoped to poll the Commission, but the notice 5
regarding polling of the Commission did not arrive until this 6
morning.
7 I regret that Commissioner Asselstine is not present 8
for this meeting, since at our last meeting he expressed great 9
interest in the topics that will be discussed today.
I was 10 informed of his planned absence late yesterday afternoon.
His 11 staff told me that he will read the transcript, 12 Before we begin today's discussion I would like to 13 reiterate that this has been a tremendous undertaking and the 14 staff should be commended for bringing it to this point of 15 fruition.
I also recognize that this effort reflects a 16 significant amount of work, not only by the NRC staff but by 17 other federal agencies, as well as other domestic and 18 international organizations.
19 Let me ask, do any of my fellow commissioners have 20 additional opening remarks to make at this time?
21 COMMISSIONER BERNTHAL:
No.
22 CHAIRMAN PALLADINO:
All right then, let me turn the 23 meeting over to Mr. Dircks.
24 MR. DIRCKS:
We'll be picking up, as you said, 25 Mr. Chairman, from the last meeting.
I do want to make sure
o 5
1 to call to your attention the memo we sent down on July 25th 2
containing revisions to 85-147 and the proposed revision of 3
Part 20.
And that was based on the EPA communication that we 4
- received, t
5 Bob, do you want to begin where we left off last 6
time?
7 MR. MINOGUE:
Thank you.
In the previous meeting we 8
provided you an overview.
In today's meeting we'd like to do 9
two things.
10 First, Mr. Cunningham and I both have gone through 11 the transcript of the previous meeting, and also have tried to 12 identify some of the fundamental radiological protection 13 principles that are important in understanding the three major 14 issues that we're going to discuss.
15 So Mr. Cunningham will start off with a discussion 16 of these principles in this application.
Following that, 17 we'll cover the three issues which the Chairman identified.
18 One reason for the lapse of time between the 19 previous meeting and this one is that we've had a number of 20 very good exchanges with the EPA as they have tried to deal 21 with -- or have dealt with one of the major issues, which is 22 the question of the protection of the embryo / fetus.
And we'll 23 cover that at some length.
24 As Mr. Dircks has pointed out, we've sent you a 25 revised paper which reflects this very definitive feedback 1
y
__m-
6 1
from EPA.
We also have sent down to you, in the interest of 2
keeping this meeting short and to the point, two background 3
papers.
One on the question of foreign applications, British 4
applications of de minimus and the other on epidemiological 5
studies.
We don't really plan to discuss those points here 6
today.
7 CHAIRMAN PALLADINO:
We got the one just a few 8
minutes ago, and I don't recall the other one.
the 9
MR. MINOGUE:
The other ones were sent down 10 epidemiological paper was sent early in June as my notes would it indicate.
And the one on -- June 25th, sorry.
12 CHAIRMAN PALLADINO:
Okay.
13 MR. MINOGUE:
And the other one on July 24th, on the 14 de minimus.
But these are really background material 15 They're not significant to the discussion that we're going to 16 have today.
And we don't plan to discuss them today.
17 Mr. Cunningham?
18 MR. CUNNINGHAM:
Thank you, Bob.
Going over the 19 transcript here, following the discussion of the last meeting 20 it became evident that there were a lot of questions about 21 radiobiology 22 MR. GOLLER:
Next viewgraph.
23 CSlide.]
24 MR. CUNNINGHAM:
-- and its bearing on the revision 25 of Part 20.
So I would like to take a few minutes just to
)
7 1
provide some background on radiobiology.
First slide, 2
please.
Next viewgraph.
3
[ Slide.]
4 MR. CUNNINGHAM:
Starting with doses above 50 rem --
5 now, bear in mind that our regulations limit occupational 6
exposure to five rem annually.
But we'll st. art with looking 7
at what happens as a result of dose above 50 rem.
8 This is -- we see a phenomena called a non-random or where the consequence 9
non-stochastic effect where the dose 10 is proportional to the individual dose.
Fifty rem is just on 11 the edge of where you see this phenomena, and it must be 12 delivered in a relatively short time.
13 What happens is that with doses of this magnitude or 14 greater you have massive destruction of cells, which impairs 15 physiological functioning of organs.
16 For example, your bone marrow is the place where red 17 blood cells are generated.
If you are subject to a high dose 18 of radiation, the precursors to the red blood cells are killed 19 and you have suppression of the red blood cells in your blood 20 pool.
The more dose, the more radiation of bone marrow, the 21 more precursors to the red blood cells are killed, the more 22 severe your problem is in red blood cell completion.
23 Of course, this very technique is used in cancer 24 therapy.
You focus the radiation on a tumor and you subject 25 it to a great amount of radiation, usually in the thousands of
i 8
1 rem to kill cancerous cells.
2 So the phenomena at 50 rem or more is massive 3
destruction of cells.
The effect is proportional to the dose.
4 At doses below 50 rem, and particularly in the range 5
in which we typically regulate doses, five rem for 6
occupational exposure and below -- next slide, please.
7
[ Slide.3 we have what we call stochastic 8
MR. CUNNINGHAM:
9 effects or random effects from radiation.
Now as opposed to 10 the severity being proportional to the dose, here we have a 11 phenomenon in which the incidence of something happening is 12 proportional to the dose.
13 You either get cancer or you don't get cancer.
But 14 the incidence, the probability of getting it is proportional 15 to the dose.
And that probability is usually roughly 16 considered to be 10 to the
-4 per rem delivered.
17 Now what happens at this level of this radiation, 18 radiation changes cellular chemistry in a relatively small 19 number of cells.
There are one of two consequences.
The 20 cells die, there's no health effect at this level Cells in l
21 your body are dying all the time.
Millions die in a day, and l
I
(
22 perhaps even billions.
Your body is constantly being 23 regenerated.
So a cell dying at this level of radiation is of 24 no particular consequence.
25 COMMISSIONER BERNTHAL:
If I could interrupt for a l
D 9
1 second as long as we're talking about fundamentals.
What is 2
the status of the best scientific thinking today on the linear y
3 hypothesis, versus linear quadratic, versus sharp cutoff
- 4 What does the community of scholars have to say about that 5
these days?
6 MR. CUNNINGHAM:
Well, the linear curve is used as 7
being probably a very conservative curve.
I believe that most 8
current thinking is that the linear quadratic curve is 9
probably the best fit of what is truly happening, although 10 they can't prove it 11 The linear curve for high LET radiation, high linear 12 energy transfer radiation, probably the linear curve is a more 13 accurate fit.
But when you get down in the dose range below 14 five rem, the linear and the linear quadratic plotted on log 15 paper run approximately parallel The difference is something 16 between a factor of two and four of effect.
But that's lost 17 in the noise of your calculational ability.
18 COMMISSIONER BERNTHAL:
So for small values they're 19 very similar, is that what you're saying?
20 MR. CUNNINGHAM:
Well, yes.
Yes, because you're 21 operating in the lower part of the curve.
They're very 22 similar and they would probably not influence a decision too 23 much one way or the other is my own guess.
24 COMMISSIONER BERNTHAL:
I see.
So if there's any 25 argument it's over the sharp cutoff question, is that the
_ _ _. ~
10 1
point?
2 MR. CUNNINGHAM:
Well, that's certainly one 3
argument.
4 MR. MINOGUE:
The EPA convened several years ago a 5
very prestigious committee, the committee on Biological 6
Effects of Ionizing Radiation, so-called BEIR committee and 7
they dealt with exactly this issue at some lengths and reached 8
conclusions much as Mr. Cunningham has said so.
9 In the sense of the scientific community, I think 10 it's fair to say that the BEIR report represents a consensus 11 of the state of this technology as of several years ago.
The 12' current issues are really more related to the mutual effects 13 and to the quality factors as they would apply to neutrons, 14 the applications of some of the data from the Japanese bomb 15 victims and so on.
16 So there is controversy but not in this context, as 17 Mr. Cunningham has said, that the range of what the scientific 18 types are discussing in a regulatory context makes little 19 difference in terms of what you do in terms of regulatory 20 actions.
It's rather narrow.
21 COMMISSIONER BERNTHAL:
Okay, thanks.
22 Go ahead.
23 MR. CUNNINGHAM:
Well, when cells reproduce 24 abnormally it can result in one of two things, a cancer that 25 continues to reproduce itself abnormally.
Or you can see
11 1
genetic defects.
2 Generally the health e'ffects are latent.
Cancer 3
appears somewhere between five to 30 years post-exposure.
At 4
least that's the point at which it's detectable with the 5
leukemias appearing at the lower end of this spectrum and 6
solid tumors appearing on the upper end of the spectrum.
7 Genetic effects, of course, show up in future generations.
8 Next slide, please.
9 CSlide.)
10 MR. CUNNINGHAM:
Dealing with the question of 11 radiosensitivity, this came up in the embryo / fetus question.
12 Not all cells are equally radiosensitive.
Generally the more 13 radiosensitive cells are the ones that. multiply rapidly or 14 have a large nucleic acid content.
Generally, they're one and 15 the same.
16 Examples of cells that multipi^y rapidly are the 17 precursors in the bone marrow, gonads, the sperm precursors 18 to the sperm cells rather -- white blood cells and others.
So 19 that bone marrow -- these are the more radiosensitive tissues.
20 Insensitive tissues, examples of them are the 21 central nervous system and the skin.
Another example of an 22 insensitive tissue would be a mature red blood cell, 23 relatively -- very insensitive to radiation.
24 Turning to the radiobiology of prenatal exposure, 25 unfertilized eggs have relatively low sensitivity.
But you do
12 1
see high radiosensitivity during the period of rapid cell 2
division.
That would be after the egg is fertilized.
3 The period of greatest risk, during the period of 4
gestation the period of greatest risk would be during 5
organogenesis which is approximately eight to 15 weeks.
6 Now there are some risks that remain relatively 7
constant over the entire period of gestation.
The risk of 8
leukemia resulting from radiation dose is an example.
9 However, this period when the organs are being formed is an 10 additional risky period laid over top of that.
So the 11 greatest period of risk is from eight to 15 weeks.
12 Looking at Part 20 there were questions about the 13 way we calculate internal dose the changes that were being 14 made in the revised Part 20 to calculate internal dose.
15 Next slide, please.
16 CSlide.]
17 MR. CUNNINGHAM:
In the proposed rule we assume, and 18 we know in fact that radioisotopes taken internally are 19 distributed among organs rather than to a single critical 20 organ.
21 The old Part 20 simply because of our calculational 22 capability at the time, no computers, because of lack of 23 radiobiological data on distribution 25, 30 years ago, we used 24.
the single organ concept which was a handy sort of thing.
But 25 now we have good data and we can deal with the question of
i
}
13 1
distribution among organs.
2 CHAIRMAN PALLADINO:
But the distribution isn't 3
uniform.
Are there not some isotopes or some elements that go 4
to specific organs in the body in preference to others?
5 MR. CUNNINGHAM:
Certainly they tend to concentrate 6
in some organs more than the other organs.
And that's why we 7
were able to deal with the single critical organ before.
But 8
it isn't quite accurate.
Iodine concentrates mostly in the 9
thyroid, but some will go other places.
Certainly other 10 materials will concentrats --
11 CHAIRMAN PALLADINO:
You take that into accou'nt?
12 MR. CUNNINGHAM:
Yes, you take that into account 13 Also, the new Part 20 includes exposure of other organs from 14 material deposited in, concentrated in a specific organ 15 because it's radiating out from the organ.
And the new Part 16 20 takes into account updated radionuclide distribution and 17 retention models.
next 18 Again, just to review the concept of how we 19 slide, please.
20
[ Slide.]
21 MR. CUNNINGHAM:
-- how we calculate or express dose 22 now in the new Part 20.
We start with the point that exposure 23 of an organ gives risk of an effect.
That's cancer, that's 24 this non-stochastic -- or the stochastic effects we were 25 talking about.
l 14 1
For a given exposure, the probability of an effect 2
depends upon the sensitivity of the organ.
Not all organs are 3
squally sensitive.
The common denominator to all these 4
different kinds of organs, sensitivity to concentration is 5
risk of an effect.
6 So what we try to do is reduce all those to one 7
common risk factor and that's called the effective dose 8
equivalent.
And what that is is the effect -- an effective 9
dose equivalent of one rem, for example, that's the amount of 10 dose, is the dose necessary in a specific organ to produce an 11 equal risk to the risk of effect of one rem of external whole 12 body radiation.
13 In other words, we're trying to reach a common 14 denominator.
If you have an intake of radioisotope into one 15 particular organ or concentrated in one organ, we're trying to 16 assess what the risk to the body is in that, and we equate it 17 to the risk of a rem of radiation distributed over the total 18 body.
It's called effective dose equivalent.
19 COMMISSIONER ZECH:
That means it could be more that 20 one rem?
21 MR. CUNNINGHAM:
Effective -- no, it's 22 COMMISSIONER ZECH:
It could be more than one rem?
23 CHAIRMAN PALLADINO:
To get the same effect?
24 COMMISSIONER ZECH:
To get the same effect, is that 25 what you mean?
15 1
CHAIRMAN PALLADINO:
Yes, that's the way I read 2
this.
3 MR. CUNNINGHAM:
Yes, yes.
The actual dose to that 4
organ would generally be more.
5 COMMISSIONER ZECH:
Right, but the effective dose, 6
or the measurable dose, or the 7
MR. CUNNINGHAM:
The effect in terms of risk of an 8
incident of cancer is the effect 9
COMMISSIONER ZECH:
Right, is worth one rem.
l 10 MR. CUNNINGHAM:
-- of this equivalent, yes.
11 COMMISSIONER ZECH:
All right, thank you.
12 MR. CUNNINGHAM:
Looking Mr. Minogue is going 13 to talk about collective dose and the de minimus -- its 14 relationship to the de minimus concept quite a bit so I'll 15 mention a few words about it.
16 This gets back to the linear theory.
For purposes 17 of radiation protection effects are assumed to be linearly 18 proportional to exposure in the stochastic range.
That is, in 19 the range of dose below 50 rem.
20 Now the collective dose is really a sum of 21 individual doses in populations to determine the risk of a 22 latent effect in the population.
This assumes that the risk 23 in the population is independent of the dose distribution, 24 provided the individuals are within dose limits or operating 25 in the stochastic range.
16 1
What this means is that if you have a dose of 10 rem 2
to a population, it doesn't matter whether that 10 rem --
3 whether your population size is 100 people or 1,000 people and 4
you distribute that dose equally over the 100 or 1,000.
The 5
risk of a latent effect of cancer is directly proportional to 6
that dose, independent of the size of the population over 7
which that dose is distributed.
That's why you --
8 CHAIRMAN PALLADINO:
That doesn't sound reasonable.
9 Maybe I need a little more background.
If the 10 rem went to 10 one individual I would expect it would have more severe effect 11 than if it's distributed over 100 people.
12 MR. CUNNINGHAM:
No.
13 CHAIRMAN PALLADINO:
No?
14 MR. CUNNINGHAM:
Ok.ay, if you think back in the 15 first slides, we say that above 50 rem the effect is 16 proportional to the dose.
You have killed a massive amount of 17 cells and you impair organ function.
18 Below 50 rem, and certainly within the dose limits 19 which we operate, five rem and below, the effect is -- or the 20 incidence is proportional to the dose.
You don't see an 21 effect in people, but you can get a cancer.
The probability 22 of you getting a cancer is proportional to the dose.
Then you 23 either get a cancer or you don't get a cancer.
24 COMMISSIONER BERNTHAL:
But that's because you're 25 talking about different types of damage.
In the one case
17 1
ycu're talking about a statistical damage to a cell that can 2
otherwise reproduce, or can reproduce cancerously.
And in the 3
second case you're talking about a visible, observable malady 4
like damage to skin or blood cells or whatever.
There's a 5
difference.
6 MR. CUNNINGHAM:
Yes.
7 COMMISSIONER BERNTHAL:,One is statistical, one is 8
not.
9 MR. CUNNINGHAM:
And the risk to an individual, if 10 you deliver that 10 rem to an individual would be 10 times 10 11 to the
-4.
That's his risk of getting a cancer, roughly.
12 If you distribute that risk -- that dose over 100 13 people, the risk of a cancer appearing somewhere in that 14 population of 100 people is still 10 times 10 to the
-4.
15 COMMIS9IONER BERNTHAL:
I have to say -- this is an I
16 aside -- but it seems to me we ought to quit using the l
I 17 terminology low level radiation dosage to apply to 100 R or i
18 less.
I mean, by any stretch of the imagination that is not a 1
19 low level dose, at least in my judgment.
l l
20 MR. CUNNINGHAM:
100 R?
21 COMMISSIONER BERNTHAL:
100 R.
22 MR. CUNNINGHAM:
To a single person?
l 23 COMMISSIONER BERNTHAL:
Yes.
24 MR. CUNNINGHAM:
I don't see where we use that as 25 low level, i
18 1
COMMISSIONER BERNTHAL:
It's scattered throughout a I can read it to you, if you'd like.
2 document that I'm 3
CHAIRMAN PALLADINO:
Which document is that?
4 COMMISSIONER BERNTHAL:
Health effects of relatively 5
low level, less than 100 R radiation.
Less than 100 R.
This 6
is a document 7
MR. MINOGUE:
Well, this relates to the two types of 8
processes which Mr. Cunningham has discussed.
When you get 9
into the lower levels you have a stochastic effect, and that f
to fundamentally is the sense in which that term is used.
11 An occupationally exposed worker working over a let's say he has a 30-year working career and 12 lifetime j
13 somehow got five rem per year for 30 years.
That adds up to a 14 fair amount.
So 100 rem as a lifetime exposure, although it's 15 admittedly at the top end of the range is within the range of i
16 occupational exposures.
I 17 MR. CUNNINGHAM:
Yes, remember for this effect, the 18 non-stochastic effect where you have massive cell destruction 19 it has to be delivered over a relatively short time, like 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, days, to get the cell destruction without repair.
l 21 MR. MINOGUE:
Right.
The term used -- normally is 22 used in the sense, in one case you're talking about prompt i
23 damage and the other case you're talking about latent damage r
24 that doesn't show up for years.
And it's a common usage of 25 the term.
19 1
MR. CUNNINGHAM:
But I've never heard 100 R to an 2
individual delivered over a short time characterized as low 3
level radiation, not at all 4
COMMISSIONER BERNTHAL:
Well, it's not characterized 5
as short or long time.
I guess the context here assumes long 6
time.
But -- yes, it does.
7 MR. MINOGUE:
Yes, if you look at 8
COMMISSIONER BERNTHAL:
But even for that, are the 9
data so clear that the cancer dose now as opposed to the or 10 the cancer risk as opposed to the cooking risk are that much 11 different for a short term exposure versus long term 12 exposure?
Are there any data to support that?
13 MR. MINOGUE:
When you get into these lower levels, 14 the rate at which you receive the radiation is not a major 15 factor in determining the risk.
16 COMMISSIONER BERNTHAL:
100 R is a lower level?
17 MR. MINOGUE:
No, no.
No 100 R in a single shot is 18 not low.
But as a lifetime exposure it's at the upper end of 19 the range of occupational exposure.
20 COMMISSIONER BERNTHAL:
I understand.
21 MR. MINOGUE:
There are workers who receive that in 22 their lifetime.
23 COMMISSIONER BERNTHAL:
I understand.
But my 24 question is, if you get 100 R,
whether it's over an hour or 25 over 30 years, are there data to support the idea that the
20 1
cancer risk is different for the two cases of exposure?
2 MR. CUNNINGHAM:
No, I think the cancer -- looking 3
at those, 100 R in a relatively short time, say over a few 4
minutes, and the 100 R over 30 years, the cancer risk is 5
probably about the same.
6 COMMISSIONER BERNTHAL:
That's what I thought.
7 MR. CUNNINGHAM:
But you will see other phenomena on 8
that 100 R delivered over a very short time.
9 MR. MINOGUE:
Exactly.
10 MR. CUNNINGHAM:
You would see blood changes, all 11 kinds of things can happen.
You're not quite at a -- you're 12 not at an LD-50.
You can see rather some severe damage at 100 13 R delivered over a very short time.
14 COMMISSIONER BERNTHAL:
And by how much, relative to 15 the general population let's take 100 R,
leave aside now since 16 we're agreed that the cancer risk is roughly the same, by how 17 much does that increase the cancer risk then over -- relative 18 to the general population over a lifetime?
I think you gave 19 the number a few minutes ago, but I can't remember what it 20 was.
21 MR. CUNNINGHAM:
I'm not sure I understand the 22
- question, 23 COMMISSIONER BERNTHAL:
If a person gets 100 R 24 compared to the general population, 100 R more, by how much 25 does his risk increase during his lifetime?
21 1
MR. CUNNINGHAM:
Well, it would be 100 times 10 to 2
the
-4.
3 COMMISSIONER BERNTHAL:
Per R,
yes.
4 MR. CUNNINGHAM:
Which is 10 to the
-2, which is 1 5
percent.
9 6
COMMISSIONER BERNTHAL:
One more person out of 100.
7 MR. CUNNINGHAM:
Well, 1 percent.
Now your risk in 8
dying of cancer in the average United States population is on 9
the order of 20 percent.
10 COMMISSIONER BERNTHAL:
Right.
11 MR. CUNNINGHAM:
So that still is a relatively small 12 contribution.
Higher than you would like to see perhaps, but 13 still a relatively small contribution.
14 CHAIRMAN PALLADINO:
What are the units of the 10 to 15 the
-4 probability?
16 MR. CUNNINGHAM:
Risk of a latent cancer, fatal 17 cancer per one rem of radiation.
18 COMMISSIONER BERNTHAL:
I guess the thing that 19 troubles me is it's -- okay, I'll grant you it's commonly used 20 and we call it low because it's used in respect to 21 occupational exposure -- is the confusion it creates, in my 22 mind at least, when we talk about low exposures being 10 or as you know, there's at 23 20, let alone 100 R.
And yet the 24 least-a small class of individuals that worries about 25 additional exposures of 10 MR per year and calls that low
22 1
level exposure.
And somehow that's --
2 MR. CUNNINGHAM:
Commissioner Bernthal, I've been in 3
this business a long time and I cannot remember a time when 4
anybody called five R,
10 R,
100 R delivered in a relatively 5
short time to an individual low exposure.
When you talk about 6
low exposure to individuals --
7 COMMISSIONER BERNTHAL:
Let's forget about 8
relatively short time.
I'm talking about anytime.
9 MR. CUNNINGHAM:
Well, low exposure is usually --
10 the context we use it in is certainly below background 11 levels.
Now low is a relative term.
If you were working in a 12 reactor where many people got up to five rem per year, a 13 person with a relatively low exposure might be somebody who 14 has half a rem in that time.
15 But normally when we talk about public exposure, low 16 is something below background radiation levels.
17 MR. MINOGUE:
Maybe it would help to give some 18 perspective.
You look 61 the worker population, these are i
19 occupationally exposed workers, typically they're in a range
)
1 20 of maybe 300 millirem per year.
That's
.3 rem up to maybe 6-21 or 700 millirem per year.
22 That's a pretty typical level for people who are 23 occupationally exposed in some significant way.
I'm not 24 talking about the trivial worker who occasionally gets a small 25 amount of exposure.
But the person who routinely works in a
23 1
radiation environment typically would be receiving exposures 2
in that range.
3 And that's really the context in which we're 4
talking.
That's the rate at which the workers are receiving 5
the radiation.
6 CHAIRMAN PALLADINO:
But I think Commissioner 7
Bernthal has a good point.
We've got to be careful on how we 8
use the words low level radiation, because I would agree that 9
100 rem is not low level, even when you think of it as being 10 something you get in a short period of time.
11 COMMISSIONER BERNTHAL:
I just think it's a 12 terminology we should avoid.
I can see this being quoted out 13 of context.
And it's not low level except for, perhaps the 14 worker who has agreed to work at relatively high levels, or 15 what would be considered high levels for everybody else.
16 CHAIRMAN PALLADINO:
But he doesn't work in anything I
17 like 100 rem per hour.
18 COMMISSIONER BERNTHAL:
No, certainly not.
But l
19 well, it's a question of terminoiscy I'm not very happy with, 20 I guess.
l 21 MR. MINOGUE:
Well, we can take a look through the 22 package.
I'm sure that this concept can be clarified.
And if l
23 it's not clear we can certainly do some minor editing to fix 24 that up.
25 MR. CUNNINGHAM:
Just to complete this thing on i
i
24 1
collective dose assessment Collective dose assessment in 2
theory takes into account all dose regardless of how small and how it's distributed over space and time.
You 3
distributed 4
integrate over total space over total time.
That's the 5
theory.
6 In practice, you have a lot of problems with dose 7
distribution pathway models to make those calculations.
You 8
talk about time, thousands, hundreds of thousands of years.
9 It becomes very difficult to predict what populations will 10 have at that time.
Population shifts influence the 11 calculations.
And future events which affect dose consequence 12 can affect calculations on which you made the distributions.
13 So the collective dose is a tool that has certain 14 practical limitations associated with it, and that's what Bob 15 will be getting,to later on.
That completes my presentation.
16 MR. MINOGUE:
Thank you, Mr. Cunningham.
I'll go 17 on to the three issues.
Let's have the next viewgraph, 18 please.
19
[ Slide.]
20 MR. MINOGUE:
The first of them is the question of 21 the protection of the embryo / fetus against occupational 22 radiation exposure.
This is a very complex issue.
It 23 inherently involves a balance between protection of the unborn 24 and the employment opportunities of the worker.
25 It's also an issue that's not unique to radiation as
25 1
a workplace environment There are many, many other workplace 2
hazards that have the same type of problem.
3 The EPA has in an advanced stage of development 4
guidance covering the area of occupational exposure.
In the 5
previous briefing we talked to the Commission in terms of an 6
interpretation of the EPA guidance as requiring the 7
implementing agencies of that guidance to make this balance 8
between worker protection and protection of the embryo / fetus, 9
which is a very difficult thing for NRC to do because of the 10 scope of our regulatory authority and the extent to which it 1i deals with employment epportunities is such it is not really 12 within 'our jurisdiction.
So this was a very tough thing for 13 us to do.
And we really errestled with that in the package 14 that we brought to the Commission.
15 Concurrently with that we approached EPA -- there 16 have been a number of discussions.
We sent them a written 17 request for guidance following the meeting which we had with 18 you.
And we got a very good answer to that.
A very, very 19 definitive answer Mr. Dircks has sent down to you with his 20 memo.
And it really lays out very, very clearly what the EPA 21 guidance would mean in terms of an agency such as ours with a 22 regulatory mission that's basically in the radiological 23 protection area.
24 So the issue is really quite clear cut.
And I'm 25 going to go ahead and really talk more about that EPA
26 1
guidance.
Next viewgraph, please.
2 CSlide.]
3 MR. MINOGUE:
No, that's the one.
Go back one, 4
please.
5 CSlide.]
6 MR. MINOGUE:
The EPA guidance was developed by EPA 7
with the so-called FRC role.
This is the function of 8
developing nationally applicable standards for approval by the 9
President.
It's guidance that is aimed not just as regulatory 10 agencies, but at implementing agencies.
Let me use the 11 Defense Department as an obvious example, who do things, or 12 the Veterans Administration in hospitals who do things 13 involving the use of radiation.
And radiation exposure is a 14 very pervasive activity.
So this guidance affects a lot of 15 agencies.
16 Reflecting that, the EPA developed the guidance with 17 the assistance of a broad-base / in'eragency working group 18 which NRC was represented on.
One of the topics they dealt 19 with in this guidance was the protection of the embryo / fetus.
20 This guidance is moving along well The present 21 status of it is that, I believe many of the agencies have 22 concurred in the final form to go to the President.
There 23 does remain one issue between the Department of Energy and the 24 Health and Human Services Department that does not really 25 affect what we have proposed to the Commission because the
27 1
package that you have before you tracks the present form of 2
the EPA guidance.
And if it were modified in this area we 3
would simply modify the guidance to conform to what EPA does.
.4 The longstanding practice of the Commission -- and 5
it goes back literally to the AEC 6
CHAIRMAN PALLADINO:
Does that mean that if EPA 7
changed its rules we'd have to change our Part 20?
8 MR. MINOGUE:
Yes, I think where there's a very 9
and that's what I was just about to touch on -- the 10 longstanding practice of this agency has been to conform to 11 FRC guidance.
Nobody has really focused on the question of 12 whether we're legally required to conform or not because it 13 has been a longstanding practice to conform to the guidance.
the staff's recommendation --
14 And it would be our that if the properly 15 I believe it's a unanimous view 16 developed FRC-type guidance which involves a very elaborate i
17 process of consultation and consideration and approval by the 18 President is really binding on t**
agency, and we would expect 19 that our regulations would conform with that guidance.
20 And if any issues arose --
21 CHAIRMAN PALLADINO:
No, what I was getting at --
t it would be how you implemented the 22 MR. MINOGUE:
J 23 guidance, rather than whether you conformed or not.
24 CHAIRMAN PALLADINO:
No, I wasn't arguing that 25 point I was arguing why don't we write our regulations so we
i l
]
i 28 1
don't have to change them every time they change their 2
standards?
3 MR. MINOGUE:
Well, normally FRC guidance once it's 4
issued stays in place for a long time.
The kind of change I'm 5
talking about might occur during the same time frame this 6
rule we're proposing to put out for public comment -- within 7
the next months, or at worst within the n e:.t year these 8
matters will be resolved.
And if they were resolved 9
differently from the present draft of the EPA guidance, then I 10 would expect that that would be just taken into account when 11 the rule goes into final form.
12 MR. DIRCKS.
I can't recall the last time the 13 President's Federal Radiation Council made a significant 14 change.
It's been years.
15 MR. MINOGUE:
Yes, in this area I believe it's 16 something like 15 or 20 years.
It's a long time.
l l
17 COMMISSIONER BERNTHAL:
That makes you wonder l
l 18 whether it isn't time to take a look.
19 MR. MINOGUE:
Well, it is.
That's why EPA is I
l 20-looking at it.
In fact, we had encouraged them to undertake 21 this some years ago.
This is right And they're very far 22 along.
They've been working on this about as long as we've 23 been working on Part 20.
And many of the products of their 24 effort are reflected in the rule that's before you because 25 we've been close to the effort.
29 1
Let me go on to the next viewgraph.
2
[ Slide,3 3
MR. MINOGUE:
The factors that they considered 4
related to this issue are first the point which Mr. Cunningham 5
covered, the fact that the embryo / fetus has a higher degree of 6
radiosensitivity.
That's reflected also in the 7
recommendations of ICRP and NCRP.
8 The EPA work group also considered the question of 9
employment rights and invasion of privacy.
So that the 10 broader issues were dealt with in that group.
11 Next viewgraph.
i 12
[ Slide.]
13 MR. MINOGUE:
This next viewgraph illustrates a and I'm not going to go through each one of these.
14 range 15 But you look here at a spectrum of different approaches that 16 could be used to the question, ranging at one end of the 17 spectrum to something that basically leaves the decision to 18 the woman, relying entirely on an understanding of the leaving the 19 radiological risk that's involved 20 decisionmaking to her.
To the other end of the spectrum where 21 you could just impose a blanket requirement on all workers.
22 And this gives some idea of the wide range of alternatives, i
23 EPA in coming down with their final position has l
at the top end of this spectrum.
24 come down somewhat on the 25 Let me go on to the next viewgraph which gives the 1
30 1
response that we got from them.
2 CSlide.]
3 MR. MINOGUE:
First, their intent was that a 4
radiation protection oriented agency like ours would impose a which is one-tenth of that of a 5
specific exposure limit of 6
normal worker during the entire pregnancy of a Jeclared 7
pregnant worker.
And that means declared by herself.
It it's not determined by some other party.
8 would be 9
Their anticipation was that the job protection 10 aspects would be dealt with separately to the extent that an 11 agency had jurisdiction, that they would deal with it more in 12 the context of job protection and equal employment rights.
13 That is the letter that Mr. Myers sent to Mr. Dircks 14 explicitly says, to the extent that they have regulatory or 15 administrative jurisdiction as being the extent to which they 16 expected agencies to deal with these job rights issues.
- Well, 17 our understanding from the lawyers is that basically the NRC 10 has no jurisdiction or authority in this area.
So we would l
19 interpret that to mean that as a very practical matter for NRC 20 that we would just impose a lower limit.
21 CHAIRMAN PALLADINO:
But this limit applies only to 22 the declared pregnant worker?
23 MR. MINOGUE:
That's right It's self-declared.
24 CHAIRMAN PALLADINO:
Now, if I remember correctly, 25 you said the effect can appear in four to eight weeks?
Did I
31 1
remember that?
2 MR. CUNNINGHAM:
The most critical period.
3 MR. MINOGUE:
The most critica1 period, yes.
4 CHAIRMAN PALLADINO:
They might not be in a position 5
to declare in that period.
6 MR. MINOGUE:
That decision would be you know, t
7 this is a difficult balance.
8 CHAIRMAN PALLADINO:
No, I'm getting at --
9 MR. MINOGUE:
On the previous viewgraph when we 10 talked in terms of fertile women, women of childbearing age is 11 a population that you could look at.
'12 CHAIRMAN PALLADINO:
No, no, I'm talking about'the 13 opportunity for the women to declare herself You might not 14 know in four to eight weeks.
15 MR. MINOGUE:
That is correct.
And that's why 1 in the previous viewgraph there was 16 said that EPA came down 17 a spectrum of positions you could take.
If you want to move 18 in the direction of greater protection of.the fetus, then you 19 start talking in terms of fertile women and not women who are 20 pregnant.
21 So EPA has consciously decided, in an offort to give 22 some consideration to the job issue I'm certain, to come down 23 in the context of self-declared pregnant women.
24 MR. CUNNINGHAM:
That critical period was eight to
(
25 15 weeks, Mr. Chairman.
32 1
CHAIRMAN PALLADINO:
Eight to 15.
2 MR. MINOGUE:
They also 3
CHAIRMAN PALLADINO:
Why is not the earlier period 4
also critical?
Because the cells are dividing and a cell may 5
be an arm.
6 MR. CUNNINGHAM:
Yes, it's certainly important.
But 7
this is the most critical period.
It's only the most critical the entire period of 8
period.
The rest of the period 9
gestation is important.
10 COMMISSIONER BERNTHAL:
So there's maximum 11
' differentiation going on at eight to 15; is that correct?
l 12 MR. MINOGUE:
That's correct.
As I said, this is a 13 very difficult balance because if you want to go entirely l
14 in terms of protection of the fetus, then you should talk in 15 terms of fertile women.
16 They also provided in this letter some explicit 17 limited flexibility in cases where during the early stages of already received the l
18 pregnancy the woman had received l
19 limit.
It would allow an additional incremental exposure, f
20 I think very importantly they, in the letter that 21 was sent to Mr. Diroks, they agreed that the guidance as it 22 had been written was in fact lacking in clarity.
And they 23 have agreed that before the guidance goes to the President for 24 approval that they will clarify these same points in the 25 guidance.
e 33 1
So I think the problem of interpretation that we had 2
some months ago disappears because they will modify the 3
guidance to reflect this very clear letter that Mr. Myers sent 4
us.
5 The staff recommendation on this matter is shown on 6
the next viewgraph.
7 CSlide.)
8 MR. MINOGUE:
And I can sum it up in a sentence.
9 That we recommend that we comply fully with the EPA guidance, 10 because this is a very broad public health issue with 11 ramifications far beyond what we regulate and it seemed really 12 appropriate that we should conform to what EPA says on this.
13 In a dd i t.i on to the fact that the longstanding Commission 14 practice has been to follow FRC guidance.
15 I'll go on to the next area.
16 CHAIRMAN PALLADINO:
What's this last one?
That 17 second one, allow an additional five-tenths rem?
basically I just didn't 18 MR. MINOGUE:
Well, that 19 repeat it.
The proposed rule would track the EPA guidance 20
< explicitly which would establish a dose limit of
.5 rem, but 21 allow flexibility in cases where the
.5 rem limit had been 22 reached in the early stages of pregnancy, 23 So that the person wouldn't lose their job.
There 24 would be a small incremental exposure allowed.
25 COMMISSIONER BERNTHAL:
Let's see, I'm confused
r 34 1
though.
Somehow we've gone through these so fast I lost what 2
happens if you don't declare yourself.
3 MR. MINOGUE:
If the woman does not declare herself 4
to be present 5
COMMISSIONER BERNTHAL:
Pregnant.
the limit -- what did I say?
6 MR. MINOGUE:
7 COMMISSIONER BERNTHAL:
Present.
8 MR. MINOGUE:
I'm sorry.
If the woman does not 9
declare herself to be pregnant, then the limit would not 10 apply.
Even if she was nine months into pregnancy.
The limit 11 applies for 12 COMMISSIONER BERNTHAL:
You mean, she can decide 13 even nine months into pregnancy how much exposure?
14 MR. MINOGUE:
She can decide that she does not want 15 the lower limit to apply to her because of a perception of her 16 job interests or 17 COMMISSIONER BERNTHAL:
I have to say I'm 18 surprised.
Is that what the government agrees on?
19 MR. MINOGUE:
That's what the EPA guidance would 20 say.
The Commission's position in past years has gone even 21 somewhat beyond that It has relied on informed consent.
22 We've had a reg guide out for years that lays out i
23 the risk to the fetus very explicitly.
But it has been left 24 to the woman and there was no special limit for pregnant 25 women.
35 1
COMMISSIONER BERNTHAL:
But if a woman is visibly 2
pregnant, or if someone, a co-worker knows her to be pregnant, 3
she is still permitted to have up to the normal worker dose 4
then?
5 MR. MINOGUE; If that's her decision.
6 COMMISSIONER BERNTHAL:
If that's her decision.
7 MR. MINOGUE:
If she chooses not to declare herself 8
to be pregnant because of concern about her job then she has 9
that right.
10 COMMISSIONER BERNTHAL:
Tough issue.
11 MR. MINOGUE:
'It's a very tough issue, very tough.
12 You know, there is a very uitficult balance here between job 13 rights, personal privacy, decisionmaking by parents versus the 14 government making decisions for them, fetal protection,i n an 15 area where the workplace hasard is actually relatively small 16 compared to other workplace hazards.
17 This is a very complex issue.
And the radiation l
18 aspects of it are really a small part.
That's why my own this is what EPA was 19 personal view is this is the kind of 20 set up to decide, just this kind of question.
And I think 21 myself we should follow their guidance on this.
22 If it's clear and explicit.
And it really it.
23 Mr. Myers letter ts, I would say, a masterpiece of clarity.
it was appended to 24 There's no question what the guidance 25 the package that Mr. Dircks sent to you.
And I think if 1
i 36 1
you'll read it you'll see it's very clear.
2 COMMISSIONER BERNTHAL:
Yes, I did look at it 1
3 certainly agree with conforming with their guidelines there.
4 So we're basically talking about a potential factor of ten 5
difference in between.
6 MR. MINOGUE:
That's correct.
As a practical matter 7
that's what it boils down to.
8 COMMISSIONER ZECH:
May I just ask Mr. Cunningham, 9
it seems to me that in a case of a woman'who would decide to 10 not declare herself pregnant for job purposes knowing that she 11 was pregnant, she would at least have in mind what are the 12 risks involved.
And you articulated the period eight to 15 13 weeks as the most risk.
But the. entire gestation period is 14 some risk.
15 If that were a, personal decision of a woman and if 16 she did receive the doses that were permissible in a 17 working in a nuclear plant, for example, or a nuclear 18 facility, are there any statistics or are there any estimates
.19 as to how much risk she would be giving to her unborn child if 20 she did receive the doses that were permissible during her 21 pregnancy?
22 MR. CUNNINGHAM:
I don't know the answer to that 23 offhand, Commissioner Zech, of the additional risk to a fetus.
24 MR. MINOGUE:
We do have a reg guide that's been out 25 for many years and has been kept up-to-date as scientific
37 1
developments occur.
It's been extremely well received by all 2
parties.
It's intended for precisely this purpose.
It's a 3
discussion of the risk during pregnancy and it's aimed at the 4
woman to help her understand what the risks are.
5 COMMISSIONER ZECH:
But what I'm trying to determine 6
is, it's her own personal decision.
She knows she's pregnant, 7
she doesn't want to lose her job.
She wants to know how 8
you know, what kind of a risk am I giving to the unborn baby.
9 All I'm trying to find out is how would she 10 determine that?
How would she -- what logic process.
And I'm 11 trying to find out 12 CHAIRMAN PALLADINO:
And what data would she use?
what risk would she -- yes, 13 COMMISSIONER ZECH:
14 what data would she use?
Do we have data that would that 15 would say 16 MR. CUNNINGHAM-Yes.
17 COMMISSIONER ZECH:
And what does that data say?
can I call on Dr. Cool?
18 MR. CUNNINGHAM:
I don't 19 Do you know the answer to that?
What the data says?
We do 20 have a reg guide on it that's made available to people who 21 might be pregnant Now I don't recall offhand just what it 22 says.
23 COMMISSIONER ZECH:
Well, how would you advise the 24 woman to make that decision, and what risk would you say that 25 she's taking if she continues to work in a radiation
38 1
environment during her pregnancy?
l 2
COMMISSIONER BERNTHAL:
Five R as opposed to this
.5 3
R.
4 MR. MINOGUE:
Yes, there are numbers in the reg 5
guide, we just don't have them at our fingertips.
The reg 6
guide discusses the rates of incidents of defects and the 7
significance of them.
It does have quantified numbers in 6
them, I just don't have them at my fingertips.
9 CHAIRMAN PALLADINO:
Are there pamphlets handed out 10 to the women workers?
11 MR. MINOGUE:
Yes, this guide has been widely 12 distributed.
It was written carefully for a lay audience and 13 it has been very well received.
14 CHAIRMAN PALLADINO:
How about sending us a copy?
15 COMMISSIONER BERNTHAL:
Don't we follow 16 MR. ALEXANDER:
This reg guide that has been out for 17 several years does give risk information to the ladies, and during 18 the licensees are expected to give copies of this to 19 the training before the ladies go to work.
The revision that the new 20 we'll be publishing very soon, before the this rule 21 rule could be published also gives comparative information.
22 Risk about smoking and drinking and things like that.
23 And these data show that the risk you, at the 24 occupational exposure limit is considerably lower, for 25 example, than taking one drink a day or smoking a package of
39 1
cigarettes per day.
2 CHAIRMAN PALLADINO:
For the unborn c h i l d'?
3 MR. ALEXANDER:
Yes.
4 COMMISSIONER ROBERTS:
Just out of curiosity where 5
do you get your comparative statistics?
6 MR. ALEXANDER:
The statistics are available in the 7
open literature that we're using.
The data for the radiation 8
effects on the 9
COMMISSIONER ROBERTS:
No, I don't mean that, I'm 10 talking about cigarette smoking and alcohol and whatever.
11 MR. ALEXANDER:
Yes, that -- we just use information 12 that's published in the open literature on those.
13 CHAIRMAN PALLADINO:
But is there information 14 published in the open literature on the effect of smoking on 15 the embryo?
16 MR. ALEXANDER:
- Yes, And those studies are based on 17 epidemiological studies that have conducted and published.
18 COMMISSIONER ZECH:
Well, are you telling us then 19 that the woman who chooses to continue working in a radiation and could receive up to the doses 20 environment has 21 permissible that if she did that during pregnancy that she 22 would have less risk than if she continued smoking or drinking 23 or things like this?
24 MR. ALEXANDER:
Yes, 5 rems per year.
25 COMMISSIONER ZECH:
So what you're saying is
40 1
MR. ALEXANDER:
Well, it depends on the amount of 2
drinking and the amount of smoking.
3 COMMISSIONER ZECH:
And we're talking about the' 4
effect on the child, the unborn child.
So you're talking the 5
risk if she did receive dosages that were permissible, it 6
would have essentially a very low risk of harming the child, 7
is that what you're saying?
8 MR. CUNNINGHAM:
No, Commissioner Zech, the risk 9
remember the figure I gave you of 10 to the
-4 per rem as a 10 risk of incidence of cancer.
11 COMMISSIONER ZECH:
Right.
12 MR. CUNNINGHAM:
I've just been told by Frank l
13 reminded me that the risk to the fetus is about 10 to the
-3 14 per rem.
So you're a factor of ten higher for a given amount 15 of radiation.
Now the dose 16 COMMISSIONER ZECH:
If she's pregnant or if she's 17 not pregnant?
l 18 MR. CUNNINGHAM:
Well, the risk to the fetus.
19 COMMISSIONER ZECH:
Right, okay, I see what you 20 mean, fine.
21 MR. CUNNINGHAM:
Not to the mother.
22 COMMISSIONER BERNTHAL:
Overall' Or what about the 23 eight to 157 24 MR. CUNNINGHAM:
No, that's overall Now the dose 25 limit to the fetus has been reduced by a factor of ten.
So
41 C
1 the overall risk comes out the same.
I can't divide it any 2
more now, I'd have to go back.
3 COMMISSIONER BERNTHAL:
Ten to the
-3 overall per 4
R.
And what about eight to 15 weeks?
Another factor of 10?
5 MR. CUNNINGHAM:
I don't know.
I just don't know 6
the answer to that.
7 COMMISSIONER ZECH:
My only point is, that this 8
information that we're talking about right now in the reg 9
guide and whatever is provided to the women should be 10 presenter in my judgment in as clear, concise layman language 11 so the woman can indeed make a choice, make a decision.
~1 2 Thats very important.
13 MR. MINOGUE:
We went to a great deal of trouble to 14 make sure it was written in language that the layman could 15 understand.
And I've gotten nothing but good feedback on this 16 guide over the years.
I've heard no complaints that it's 17 incomprehensible or unclear.
18 COMMISSIONER ZECH:
How does the new revision affect 19 this issue?
20 MR. MINOGUE:
It's more expanded.
21 MR. ALEXANDER:
The main thing about the new 22 revision is it talks about an effect that we didn't know about 23 in 1975 when we wrote the old one.
And that's the effect 24 observed among some of the people who were in the womb at the 25 time of the atomic bomb explosions in Hiroshima and Nagasaki
d I
42 1
Many of the children had larger head size and some 2
retardation.
3 So we have some risk factors on that effect now.
4 And we do tell the ladies about that in this -- in the 5
appendix that goes with this reg guide.
And we, once again, 6
give them information that let's them compare this effect with 7
exposure to other agents that damage the embryo and fetus.
8 COMMISSIONER BERNTHAL:
I would go beyond that 9
though.
Rather than " making it available" and giving it to 10 them, I'm surprised that we wouldn't maybe the word is 11 continue a requirement for a signed statement that says you're
?
12 read the materials.
Informed consent, if you will 13 Do we do that?
Or are we going to do that?
14 MR. MINOGUE:
No, we do not have such a requirement.
15 CHAIRMAN PALLADINO:
Then how do they declare their 16 pregnancy?
They just say I'm pregnant or do they sign a piece 17 of paper and give it to the radiation protection people in the 18 plant?
19 MR. ALEXANDER-In writing.
l 20 COMMISSIONER BERNTHAL:
Why don't require a these don't need to be a 21 signature that, yes, you've read 22 very big and long and wordy brochure.
4 23 MR. ALEXANDER:
Commissioner, that recommendation i s 24 made in the reg guide.
The regulation itself is in Part 19, 25 paragraph 1912 on training requires that the training by
I O
43 1
commensurate with the hazard.
Broad statement.
2 In the reg guides we tell people one way to comply 3
with the regulations -- and the reg guide says one way is to 4
give them this appendix and to ask them to sign that they've 5
received it.
6 COMMISSIONER BERNTHAL:
But let's take the case of 7
the eight to 15 week period.
You've said it's a tenth of a 8
percent per R for the fetus, as opposed to 10 to the
-4 per 9
R Let's make a guess -- maybe someone here knows that it's 10 ten times higher yet during the eight to 15 week period.
11 Now you're talking 1 percent.
And one can well 12 imagine picking up a couple of R or three during that period.
13 And you're now talking a significant increase in risk just 14 during that period.
15 MR. CUNNINGHAM:
The eight to 15 week period is just 16 really emerging and getting information on this in.
Let me 17 c a l '. on Dr. Cool.
I t'hink he migh+ be able to shed a little 18 bit more light on the statu.
S' research on the eight to 15 19 weeks.
20 MR. COOL:
A lot of this research has been conducted 21 in the last couple of years.
The recommendations of ICRP 22 which were brought out in late 1983 were based on British work 23 by Atakat and Scull in the British Journal of Radiology.
That 24 was published in 1983, 25 I do not believe they have actually quantified,
44 1
provided a number for that increased risk at this point.
2 That's the subject of ongoing risk -- ongoing research.
3 COMMISSIONER BERNTHAL:
Is there any -- but there 4
must be some indication of whether we're talking an order of 5
magnitude or factor of two.
Or is there not at this point' 6
MR. COOL:
I believe it's somewhere between those 7
two numbers.
That's a very vague answer.
I apologize for 8
that, but they have not quantified it in great detail yet 9
because they have a very small sample size that they're 10 working with, i
1 11 They've observed an increase.
And as was pointed epidemio' logy which was sent down to you, 12 out in that paper on 13 with very small sample sizes you have trouble making an 14 accurate prediction on what the actual increase would be.
15 COMMISSIONER BERNTHAL:
The problem that you have to 16 is -- I suspect -- I'm guessing now -- are statistics and the 17 data you have available for this sort of thing for radiation 18 exposure at those levels must be far less satisfactory than 19 you have for cigarette smoking or alcohol consumption where l
20 you have large population studies that are statistically 21 MR. COOL:
That's true.
22 MR. MINOGUE:
And your competing factors are very 23 large, too.
So it's really difficult 24 COMMISSIONER BERNTHAL:
I have to say that I tend to 25 agree with the line that I think Lando was approaching here.
45 1
Surely they should be offered, and are I understand, the 2
information.
But I'm wondering if we shculdn't go beyond that 3
and require some sort of assurance that it's been read.
4 MR. MINOGUE:
That would be fair.
Later on I'll I
1 5
come to a revision of Part 19 that would be something we would 6
initiate very soon.
And that could be very well picked up 7
there.
8 CHAIRMAN PALLADINO:
It wouldn't be in Part 20?
9 MR. MINOGUE:
No, it would rea'11y be in Part 19.
10 MR. COOL:
If I might interrupt for a moment.
I can 11 speak for our fuel cycle licensees.
I work with the uranium l
12 fuel licensing program, and this information is provided as 13 part of the training.
We require that our licensees conduct 14 training.
We require that our licensees also have a 15 documented record that the training has been received and 16 understood, usually in the form of a written test 17 So while indirect -- it's not as direct as I think specific signed statement that I 18 vou're looking for 19 understand this par *tcular point, there is --
20 COMMISSIONER BERNTHAL:
Is that true in every power 21 plant as well?
22 MR. COOL:
I cannot speak for the power plants.
23 COMMISSIONER BERNTHAL:
Well, I think it's --
24 MR. COOL:
Frank is nodding yes.
25 MR. MINOGUE:
This guide is -- the percentage of the
46 1
population that is female in the power plants is relatively 2
lower.
But to my knowledge this guide has been widely used in l
3 every regulated sector.
4 MR. DENTON:
I think the same practice is followed l
I 5
in reactors.
6 COMMISSIONER BERNTHAL:
Is it?
All right, I wasn't 7
sure.
8 CHAIRMAN PALLADINO:
The signing?
9 MR. DENTON:
On the signing -- other than the you had to have evidence of the training 10 training prcgram l
l 11 program has been carried out.
12 MR. COOL:
Some sort of documentation that the 13 training program had been received and understood.
14 CHAIRMAN PALLADINO:
It's one thing to have my 15 teacher tell you that I understood it, and for me to tell you 16 I understood it.
17 MR. DENTON:
Well, the point I think that needs to 18 be stressed is up to now we're not required that women declare 19 whether they're pregnant or not In other words, up to this 20 time we've been operating under the informed consent basis.
21 If you adopt the new approach here, maybe there would be --
22 CHAIRMAN PALLADINO:
What's the difference between 23 informed consent?
24 MR. MINOGUE:
Informed consent really left it 25 entirely up to the woman.
And that was the Commission's
47 1
position in the past.
They must know the facts.
That's why.
2 this guide was written.
They decide.
3 CHAIRMAN PALLADINO:
But now the only difference now 4
is that the individual has to declare herself.
5 MR. GOLLER:
Yes, but once having done that, now the 6
responsibility becomes that of the licensee employer.
The 7
burden shifts when the woman declares herself.
8 MR. DIRCKS:
I think when we get to Part 19 we can 9
pick this up.
I think the Commission does want something more iO explicit and we'll just handle it that way.
11 COMMISSIONER EERNTHAL:
May I make one other comment 12 here?
I have to observe first of all that it's amusin'g th-l 13 there are all males sitting around this table here d i s c u s s t n.,
14 these issues.
I guess that's the way life is.
Shouldn't be, 15 but is.
16 Why are we talking about the possibility of losing as be'ing an element of the decision of 17 your job over 18 assuming between
.5 and 5 R burden?
19 MR. MINOGUE:
The term I used earlier on the 20 viewgraph, I believe was loss of employment opportunity, And 21 I think that's your real bottom line.
It's a question of 22 career paths and not having the opportunity to move into 23 career paths.
24 It's very difficult for an employer to deal with the 25 problem of a work group that is restricted to a much, much
48 in making a 1
lower level And there's natural tendency to 2
choice among different candidates for a position, to pick 3
people where those restrictions don't apply.
4 COMMISSIONER BERNTHAL:
For a nine-month period 5
there can be a significant consideration of employment path or we did say loss of job many times.
Now we're saying loss 6
7 of job opportunity.
But there are enlightened societies in 8
the world that make provisions for such things.
9 MR. DIRCKS:
Well, I think, you know, we're moving a 10 little bit out of our realm of regulation.
I think what's 11 trying to be said here is that sometimes employers will use 12 any excuse to move people around.
This may be one of them.
13 If the employee does have a complaint, I think, then 14 they bring it up through the other channels of regulation.
15 Probably not through our radiation regulation.
But certainly 16 they could use the EEOC and others.
17 COMMISSIONER BERNTHAL:
Well, I agree it's out of it's sort of out of our realm, I guess.
But the point 18 our 19 is, that it's being used as a major justification that runs 20 throughout the discussion we just had here of why you should 21 allow someone to have the option to go to 5 R.
And one 22 wonders if you had assurances that there would not be an 23 effect on the job whether you would make that choice if you 24 were informed.
25 MR. MINOGUE:
Well, I believe it's a factor
49 1
personally.
I also am aware -- I don't have the specifies at 2
my fingertips, but there was an assessment made several years 3
ago.
Dr. Marcus who's on my staff was associated with this 4
that the ANS carried out.
5 And my understanding is that the conclusion was that 6
there was a real potential here for inhibiting job 7
opportunities.
It is not an imaginary problem.
It's a real 8
problem.
9 COMMISSIONER BERNTHAL:
Well, I'm willing to believe 10 that.
11 MR. MINOGUE:
It's a difficult balance that has to 12 be found.
In effect, EPA has come down on that balance with 13 some provisos that do provide s6me protection in terms of 14 maintaining job opportunity.
15 COMMISSIONER BERNTHAL:
I guess there's nothing we 16 can about that.
17 CHAIRMAN PALLADINO:
Well, why don't we go on?
18 MR. MINOGUE:
Yes, let me go on to the de minimus, 19 MR. DIRCKS:
Beyond our 20 minutes today.
20 MR. MINOGUE:
Yes, we took longer on that than I had planned so I'm going to have to try to move ahead here.
21 22 The next question relates to the de minimus 23 concept.
Let's go to the next viewgraph.
24 CSlide.]
25 MR. MINOGUE:
I'm not enthusiastic about this legal
50 1
term de minimus.
I'm not sure it's a fully appropriate term.
2 What we're talking about here is the concept of a dose which 3
has a risk so low that it doesn't warrant regulatory 4
attention.
That is, a risk that is so low that it is not 5
appropriate to expend societal resources to regulate that 6
area.
It's simply not warranted.
It's not a quasi-threshold 7
that doesn't imply that there's no risk at all.
8 There are many potential applications of the de 9
minimus concept.
And certainly in no case is it a single 10 number that applies in all cases.
It is a fact that in the 11 FRC guidelines which we were talking about earlier there is 12 not any explicit reference or application of the de minimus 13 concept 14 But the concept of levels where regulatory attention 15 is not required is a longstanding concept that's been widely 16 applied.
In our regulations there are a number of exempt 17 quantities and exempt applications explicitly stated that there was an action taken several 18 radioactive materials 19 years ago with the then functioning Federal Radiation Policy 20 Council that exempted two waste forms involving carbon 14 and 21 tritium from regulatory action related to their disposal 22 So the idea of a level of exposure which has a low 23 enough risk to not warrant regulatory attention is not a 24 radically new concept.
The proposed rule that we have put 25 before you applies this concept only in a very, very limited
51 1
way.
2 And that is to the application -- the application is 3
to the calculation of collective dose assessments which can be 4
a major factor in deciding the balance between individual 5
exposure, for example to the worker who works with the waste 6
handling equipment and the population dose in deciding what 7
are ALARA levels.
And similarly in making decisions among 8
different methods that might be used for providing radiation 9
protection, either in terms of the relative costs or the types 10 of countermeasures used.
11 Let's go to the next viewgraph.
12
[ Slide.3 13 MR. MINOGUE:
Even there there's a precedent.
We 14 already limit the calculation of collective dose, we and 15 EPA in several ways.
So I think there's been a recognition 16 for some time that when you begin to get into what are really 17 fairly artificial applications of the collective dose concept 18
-- when you're looking at very, very large populations and 19 ignoring, as Mr. Cunningham pointed out, many of the 20 uncertainties involving dispersion paths or exposure pathways, 21 or if you look at very, very long periods of time, ignoring 22 there the potential that there may be some cure form for 23 various forms of cancer or the exposure pathways might be 24 modified.
25 There is a problem of getting into an artificiality
i
+
52 1
of analysis which if you then begin to use that analysis as 2
feedback to make very practical decisions on the exact 3
measures that you adopt in terms of waste handling or handling 4
mill tailings or whatever, you really have to wonder if you're 5
using the country's resources in the right way, 6
And fundamentally that's the concept this is aimed 7
at.
To provide a calculational cutoff which could be applied 8
to limit the scope of analyses involving collective dose.
9 CHAIRMAN PALLADINO:
And what is collective dose 10 again?
You mean --
.11 MR. MINOGUE:
Collective dose is the interval of the 12 exposure and the population exposed.
13 CHAIRMAN PALLADINO:
And what is the limit?
What is 14 the de minimus limit?
15 MR. MINOGUE:
The cutoff would be based on the 16 exposures at one millirem per year to an individual 17 COMMISSIONER BERNTHAL:
How did you arrive at that 18 number?
19 MR. MINOGUE:
I've discussed the concept, I haven't 20 discussed the number.
The number is a fairly -- it's a 21 different question.
It's one of the thing I would expect to 22 get some public comment on.
l 23 There was a lot of staff debate about this.
You can l
24 rationali=e that number in relationship to mome FDA guidelines j
l l
25 that were -- in terms of exposure to various drugs or things l
53 1
of that type that is reasonably comparable to the figure.
2 That is, the FDA figure was 10 to the
-6 lifetime risk of a 3
fatality,,and that's in the same range as this number here.
4 MR. CUNNINGHAM:
A lot of people have looked into 5
this for various reasons.
And it seems that somewhsre between 6
10 to the
-6 and 10 to the
-8 risk from any kind of cause, 7
people will not take actions to protect themsc.ves against 8
it.
It's a risk so trivial that they wo.i't alter what they do 9
in their daily lives to protect themselves against that.
10 And that's somewhere -- actually it's probably 11 between 10 to the
-5 and 10 to the
-8, somewhere in there.
12 This 10 to the
-7 was in that range.
13 MR. MINOGUE.
From the-beginning of this I've always 14 seen this as one of the major things we'd get feedback on in 15 the public comment process.
16 MR. GOLLER:
I think that's right.
17 MR. MINOGUE:
For societal acceptability.
And when 18 you talk radiation, actual risk and perceived risk are not the 19 same thing.
The perceived risk is going to make the societal 20 decision.
21 COMMISSIONER BERNTHAL:
The British have adopted 22 five MR, as I understand it.
And whether one MR or five MR is 23 appropriate, it seems to me that you can make the FDA type I
24 argument, but there is a difference.
And that is that as far as we know at least, 25 guess I can say this for sure
54 1
absent documentation to the contrary, we don't have the sort 2
of universal randomly distributed dosages to drugs in the 3
population.
Generally you decide when to take a drug and when 4
not to take it.
Whereas with radiation you do have a 5
universal, randomly fluesuating and distributed dosages of 6
radiation.
7 And one wonders whether the de minimus levels 8
shouldn't somehow be keyed to that.
As you know, that's cne 9
of the proposals that's been made.
And it seems to have a lot 10 of merit to me.
11 MR. GOLLER:
For purposes of this collective dose 12 cutoff, the British have adopted
.5.
13 COMMISSIONER BERNTHAL:
.5, I'm sorry.
14 MR. GOLLER:
.5 and one where you're only going to 15 do it for one particular case they explained.
16 COMMISSIONER BERNTHAL:
I see.
17 MR. MINOGUE:
I think there really are two questions 18 here and they're separable.
One is, should you accept the 19 concept of a cutoff?
And the other is, if you decide to 20 accept that, what should the level be?
And it's a lot less 21 obvious what the answer to the second question is.
I think 22 that's where the public comment process really should come in.
23 MR. GOLLER:
But by the same token, the answers th.t 24 you get and the use of this is not very sensitive to whether 25 the number is
.5 or one or even five It is not sensitive to
55 1
that.
It's the application of the concept at all that is 2
important.
3 COMMISSIONER BERNTHAL:
Yes, I agree.
And also then 4
how you decide or whether you're going to try and have a 5
rational basis at all And it seems to me there's a flaw in 6
the logic for the FDA type argument that I've just outlined.
7 This is a little different because you could look at natural 8
fluctuations and natural hazard and set some sort of 9
statistically reasonable additional increment based on that.
10 CHAIRMAN PALLACiNO:
Is anybody pushing for any 11 higher number than one millirem per person?
Other countries?
12 MR. CUNNINGHAM:
Well, it depends on who you listen 13 to.
Some people in this country have argued that it should be 14 the dose limit for members of the public.
It's up around 15 500 millirem.
And there,are others that will argue it's 16 supposed to be down to
.01 millirem.
But somewhere between 17 one millirem -- or let's say 10 millirem and a tenth of a 18 millirem seems to be what most people use.
19 Again.though, you have to be very careful about the 20 relationship of the number you pick and how you're going to 21 use it.
Because people have a lot more applications of this 22 de minimus -- and I agree with Mr. Minogue, I don't like the 23 use of the term de minimus.
It's trivial dose, perhaps.
24 But how they're going to use it.
This is used in a 25 very limited, specific way.
And as I think Karl Goller said,
56 1
it isn't -- it won't be too sensitive to -- the answers you 2
get will not be too much influenced whether or not you use a 3
tenth of a millirem or even five m,illirem.
From one millirem 4
it's --
5 CHAIRMAN PALLADINO:
But the proposal is to get 6
comments on the one millirem?
7 MR. CUNNINGHAM:
That's correct 8
MR. MINOGUE:
Yes.
9 COMMISSIONER ZECH:
But this is a figure that --
'10 this is a number that's arrived at, I presume, that's above 11 the normal radiation levels that we live in all the time.
In "12 other words, if somebody --
13 MR. MINOGUE:
It's well below them.
14 COMMISSIONER ZECH:
Yes, that's what I mean.
But I 15 mean, one millirem -- what if some, what if everybody in a 16 certain part of the country were, you know, where they live 17 way above sea level lived with dosimeters their entire year?
18 Or somebody who was flying an airplane an awful lot at high 19 altitudes.
What if they use a dosimeter in their pocket a 20 full year?
What kind of a dose would they get?
21 MR. MINOGUE:
Flight attendants, somebody like that 20 who flies for a living in a sense, yes, the figure I've seen 23 is about 100 millirem per year.
24 COMMISSIONER ZECH:
Right.
25 MR. MINOGUE:
Additional exposure from flying so
57 1
much.
2 COMMISSIONER ZECH:
Right.
But 100 milltrem per 3
years is -- I mean, I've heard that number used before too.
4 But so here we're talking one millirem per year.
And I 5
' presume this one millirem though is from a specific facility 6
or activity --
7 MR. MINOGUE:
Yes, specific source.
8 COMMISSIONER ZECH:
-- involved with nuclear 9
material That's what we're talking about 10 MR. MINOGUE:
Right.
11 COMMISSIONER ZECH:
But recognizing that many 12 citizens of our country live in an atmosphere where they get 13 perhaps, you know, maybe not 100 millirem per year but 14 certainly something in that vicinity.
15 MR. CUNNINGHAM:
You roughly double the background 16 dose moving from the East Coast to Denver from about 100 to 17 200.
18 COMMISSIONER ZECH:
Right.
19 MR. MINOGUE:
Another way people had talked about 20 arriving at this number, rather than try to relate it to other 21 risks is just to take a fraction of background.
22 COMMISSIONER ZECH:
So you're really talking about 23 really a very trivial number is what you're trying to tell 24 us.
25 MR. MINOGUE:
Take 1 percent of background.
58 1
COMMISSIONER ZECH:
It is very trivial indeed.
2 MR. MINOGUE:
Well, I don't like the word trivial in 3
this context.
4 COMMISSIONER ZECH:
But it's measurable.
5 MR. MINOGUE:
Doesn't warrant regulatory action.
6 Trivial implies a pseudo-threshold.
7 COMMISSIONER ZECH:
What's your word for it?
8 MR. MINOGUE:
That's not what we're saying.
9 COMMISSIONER ZECH:
You don't like de minimus, you 10 don't like trivial, what do you like?
11 MR. MINOGUE:
Does not warrant regulatory action.
12 COMMISSIONER ZECH:
You don't have any other term 13 than that?
14 MR. MINOGUE.
No.
15 COMMISSIONER ZECH:
Just it does not warrant 16 MR. MINOGUE:
We're using de minimus because that's 17 the term that has arisen, but it's --
18 COMMISSIONER ZECH:
De minimus then satisfies that 19 for lack of a better term.
20 MR. MINOGUE:
No.
It's a term of art that everybody 21 uses.
22 COMMISSIONER ZECH:
Okay, fine.
23 MR. MINOGUE:
I think it's unfortunate because it we're really talking about 24 raises a question that the 25 levels where you've made some conscious determination that
59 1
they're sufficiently Icw that it doesn't make any sense, in 2
terms of applying or expending public resources to regulate 3
those activities That you should put your regulatory 4
activities into other areas.
5 COMMISSIONER ZECH:
Sure, fine.
6 MR. MINOGUE:
That's really what you're talking 7
about.
8 MR. GOLLER:
I think we're up to some --
9 MR. MINOGUE:
It doesn't say you're saying that 10 there's no hazard.
11 MR. GOLLEE:
It's important to understand clearer 12 the very limited application that we're proposing.
This is to 13 cut off the calculations that are done to collective dose 14 which by the use of mathematics and computers you add in the 15 very large populations at very, very low doses.
But when you 16 add them all up, they add up to larger numbers.
17 COMMISSIONER ZECH:
Fine.
18 MR. GOLLER:
And to cut that off.
19 CHAIRMAN PALLADINO:
And what's the consequence of 20 doing that?
Save money?
What are you saving?
21 MR. MINOGUE:
You put your attention in regulation 22 in other areas.
Because if you require a licensee -- let's 23 say you're looking at a mill tailings issue.
If you look at 24 the population of the earth you're going to end up with 25 approaches and thicknesses of cover or types of cover that
60 1
might be quite different from what you would use if you were 2
looking at some different population.
3 I think the real question with this is you may be I look at it as Itke 4
diverting your attention away from the 5
a bank account of regulatory resources that you're expending.
6 Just like the agency has a limited budget You want to your 7
money where it does the most good in terms of minimizing 8
public hazard.
because the 9
When you get into these artificial 10 uncertainties in the calculations as Mr. Cunningham points 11 out, really become ' staggering when you begin this long
'12 outreach in terms of areas or lengths of time.
The same thing 13 applies in terms of years into the future.
14 And most people, in fact, have been finding a way to 1
15 limit the extent to which you reach in areas, or as I 16 mentioned in one of the viewgraphs, what this rule would do 17 would be to take that concept and codify it.
To say that 18 there is a cutoff point beyond which you do not carry out 19 these collective dose calculations.
20 CHAIRMAN PALLADINO:
Well, it will be interesting to 21 see what kind of comments you get on the number.
I 22 MR. MINOGUE:
Let me -- before we leave de minimus I'm not going to spend a lot of time on -- the next slide 23 24 reflects the material that's in the statement of 25 considerations that basically requests public comment on a l
61 1
much more complex issue.
And that's the issue of de minimus 2
exposures as they might relate to individuals.
3 And here the pattern is even more complex because 4
waste can be reprocessed and recycled and the form change.
5 They can be concentrated.
They can be distributed to people.
6 MR. GOLLER:
We're on viewgraph 21 7
[ Slide.]
8 MR. MINOGUE:
And basically in this package we're 9
soliciting comments on this issue.
But there's nothing in the 10 rule that would apply such a de minimus.
So in view of that 11 let me 12 CHAIRMAN PALLADINO:
Well, then what would you do 13 with these comments?
Would.you propose something --
14 MR. MINOGUE:
We would consider them in further 15 action or possibly work -- in parallel with this we've had a 16 number of exchanges of correspondence with EPA to get them to 17
-develop federal radiation guidance on what, in effect, amounts 18 to the determination of acceptable levels of residual 19 activity, or acceptable levels that might relate to the reuse 20 of the material that has some scrap value.
01 CHAIRMAN PALLADINO:
But now suppose you get a lot 22 of comments favoring de minimus level for individuals.
And j
l 23 let me even assume there's a great consensus on the number.
24 What would you do?
Would you have to go out and propose a new 25 rule, a new revision?
j
1 62 1
MR. MINOGUE:
I think it's likely because of the 2
approaches we made to EPA that it would be more likely to be 3
folded into an EPA proceeding.
Because we've asked them in 4
very strong terms to develop generally applicable guidance 5
that people could then use looking at specific activities that 6
they regulate or that they do in determining the appropriate 7
de minimus levels for the activities that they regulate.
8 There's not one number you're talking about.
I 9
mean, you realize it's a whole group of numbers because it 10 depends on the activity or the types of exposure.
So as we're 11 working with EPA to try to get them to deal with this issue, 12 which is critical in terms of decommissioning or the reuse of 13 recycle of contaminated --
14 CHAIRMAN PALLADINO:
What I was getting at is if you 15 do get comments on this you can't include in your final rule.
16 MR. MINOGUE:
We would not expect to include them in 17 the final rule, no, s i'r.
I'm sorry, I didn't understand your 18 question.
No, they would either be folded into a later 19 rulemaking of the NRC or I think more likely folded into the 20 interfaces that we have with EPA.
21 COMMISSIONER BERNTHAL:
Could you explain, I'm a 22 little bit lost on this.
What's the concept here?
That you 23 try and determine the maximum exposure that any individual 24 could have8 I'm not sure I understand the application to 25 individuals here.
63 1
MR. MINOGUE.
Well, that's one of the problems.
To 2
determine the maximum exposure means that you fully understand 3
the pathways.
And most of the work that's been done on that 4
is in terms of uncontrolled release.
But if you get into a 5
mode of reuse of material, which I think is the most difficult 6
issue, then the pathways may be modified.
7 You know, you may -- this is what, in the past 8
people sometimes have called technological enhancement.
You 9
may actually concentrate that material because of 10 metallurgical processes or by marketing practices.
You may 11 move it to where people are, like the cobalt 60 source that 12 got redistributed in the form of lawn furniture.
13 COMMISSIONER BERNTHAL:
Right.
14 MR. MINOGUE:
So that kind of issue has to be dealt 15 with because if you exempt material from further regulatory 16 attention, either in terms of unrestricted access, or 17 unrestricted release, or unrestricted reuse, you have to deal 4
18 with the fact that there are a number of pathways with which 19 individuals cam be exposed.
20 In determining these and deciding how far you go in 21 analyzing how these are dealt with is a very, very complex 22 issue.
And one we've been trying to get EPA to take squarely.
23 COMMISSIONER BERNTHAL:
I'm surprised at the 24 statement here that, for example, that cost reductions would 25 he appreciable for rad waste disposal as one example.
You'd
64 1
think that having to go through and demonstrate all possible 2
pathways and show that no individual gets more than, let's say 3
one MR would be incredibly expensive.
4 MR. M IfJOGUE :
Well, exactly.
That's the issue that 5
EPA has to deal with, I think.
How far do you go in the 6
analysis before you say you've done a good enough job is where 7
we need guidance.
8 Let me give you an example of how the cost could be 9
appreciable.
I mentioned earlier, a few years ago there was a 10 decision made regarding the carbon 14 and tritium waste 11 related to laboratory animals and some other application which 12 I've forgotten, which together accounted for, I believe, 13 almost half the volume of low level waste.
Mr. Cunningham can 14 correct me.
15 Yes, almost half of the volume of low level waste in 16 this country was in those categories.
And when the decision 17 was made by the Federal Radiation Council that those 18 categories represented quantities that did not require 19 regulatory attention the volume of low level waste that had to 20 be stored was cut almost in half instantly.
So it had a big 21 impact.
22 It was also very well received by the public.
I'm 23 not aware of any major opposition to that.
24 Well, I think if I may I'll go on to the next one.
25 And in two minutes I'm going to run over time and Mr. Roberts
65 1
will be proved right and I will be proved wrong.
2 Let me talk about the reporting of worker doses if I 3
may.
Here there are two issues.
One relates to the reporting 4
of doses to the NRC and the other relates to the reporting of 5
doses to the workers.
I'll discuss that second question 6
separately because the EPA guidance deals with that and also 7
because that's something that would be picked up in a revision 8
to Part 19.
9 Let me summarize on the next viewgraph what the 10 present work -- present reporting requirements are.
11
[ Slide.]
12 MR. MINOGUE:
First, we require seven categories of and these were selected as the groups whose 13 licensees 14 workers were considered to represent the highest risk -- to 15 provide us with annual st,atistical summary reports of 16 exposures.
17 In practice, to really illustrate how this works as 18 NRR implements this, the reactor licensees report exposures in 19 worker categories that relate to particular types of 20 activities.
That is, reactor operations and surveillance, 21 routine maintenance, in-service inspection, special 22 maintenance, waste processing, and refueling.
Those are the 23 categories in which people report exposures.
l 24 So it provides a statistical base that you can use 25 to analyze what the groups of activities are in the plants
66 1
that may involve significant trends either up or down in terma 2
of exposure.
3 There are also requirements from the same sets of 4
licensees that the dose for individual workers be reported as 5
they terminate employment.
Reports are required when limits 6
are exceeded.
7 Any worker under Part 19 has access to or can get 8
from a licensee his exposures.
But he has to ask for it.
The 9
licensee is not required to report it unless it's asked for.
10 And last the worker gets a report whenever NRC gets a report 11 which names him as an individual 12 CHAIRMAN PALLADINO:
And what do we do with that?
13 Just store it?
14 MR. MINOGUE:
The next viewgraph talks about the 15 staff uses of this data.
16
[ Slide.]
17 COMMISSIONER BERNTHAL:
Let me ask a question 18 related to this and another ongoing rulemaking.
If we adopted 19 the provision in our backfitting rule that applies the 20 backfitting criteria to rulemaking, the threshold criteria, is 21 there a chance that this would be judged to be cost 22 effective?
Cost benefit analysis would show that it's cost 23 beneficial to do this?
24 MR. DIRCKS:
The reporting?
25 COMMISSIONER BERNTHAL:
The reporting requirement.
67 1
The once a year you have to tell every worker how much 2
exposure he's had.
Because I assume that that's sort of a 3
political decision in the good sense of the word.
4 MR. GOLLER:
I think I can speak to that, sir.
I 5
think there's no question that it would be shown beneficial 6
It requires very little effort on the part of licensees.
And 7
actually they are probably the bigger users of the information 8
than we are.
We collate the information, put out the report, 9
the information annually.
And the licensees are all on the 10 receiving list of that.
11 COMMISSIONER BERNTHAL:
There's no question it would 12 be beneficial The question is, would it meet the cost 13 benefit criteria?
14 MR. GOLLER:
Well, the additional cost to them is 15 only sending it to us.
They all keep the information and 16 actually much more anyway.
17 MR. MINOGUEr Reporting it to the workers 18 COMMISSIONER BERNTHAL:
It's not obvious to me that 19
-- I don't think it's as easy as that because sending it 20 involves expense.
And the question is how you add up the 21 benefit.
And under our backfitting proposal that's what you 22 would be required to do.
23 And I think there's a serious question whether this 24 particular kind that's a good example, I think, of something I can well imagine, without having the 25 that I can imagine
\\
l 68 and I realtze you haven't been asked to do this 1
numbers 2
could well imagine would not meet the criteria, but then would 3
be prohibited under the Commission's proposed backfitting 4
rule.
5 MR. GUY CUNNINGHAM:
I might point in partial answer 6
to your question that CRGR did look at that question as to 7
whether this is cost beneficial under their usual criteria, 8
which are roughly the same as those in the backfit rule.
And 9
they found that it would be cost beneficial 10 COMMISSIONER BERNTHAL:
Okay.
It doesn't change the 11 point of the hypothetical.
It may be that in this case it 12 is.
It's not obvious 13 CHAIRMAN PALLADINO:
You might be interested in how 14 they did it.
15 COMMISSIONER BERNTHAL:
Yes, I might be.
16 CHAIRMAN PALLADINO:
What costs they used and what 17 benefit.
18 COMMISSIONER BERNTHAL:
My point is though that such 19
-- I doubt you're relying very much on a cost benefit analysis 20 in promulgating this rule.
And justifiably so.
You 21 shouldn't.
It's a judgment.
22 MR. DIRCKS:
There was a good deal of debate about 23 this rule within -- going on a number of years.
It's the cost 24 impact versus what are we going to get out of the rule.
And I 25 think you hit
69 i
MR. MINOGUE:
I think there's some confusion here.
2 This proposed rule does not change the present reporting 3
requirement.
4 COMMISSIONER BERNTHAL:
No, you don't understand.
5 I'm not questioning -- nor would I think of questioning that 6
workers should be informed every year.
That's not my point.
7 My point is rather the proposed rule on backfitting.
8 Let's imagine that this particular rule which could 9
very well not be judged to be cost beneficial, but which I and you are, I presume, prepared to argue 10 would argue 11 you should carry through on because we think it's a wise thing 12 to do.
That a worker should know every year what his exposure 13 is.
Call it political in the good sense, if you will, but 14 that's good judgment 15 But under the proposal that the Commission has 16 before it on backfitting, it would be very difficult to 17 promulgate the rule based on that kind of good judgment.
New 18 I'm not talking about what we're doing.
What we're doing here 19 is right.
20 MR. MINOGUE:
Let me first disagree with 21 Mr.
Galler.
I don't think that a regulation that required the 22 worker to be informed would have any major impact on our 23 regulatory operation.
If we propose to do that in another 24 rulemaking in Part 19 it would be to comply with the EPA 25 guidance.
70 1
As far as the NRC is concerned, the present that's what I was going to deal with on this 2
reporting 3
viewgraph -- gives us an information base that you can use to 4
assess the areas of operations that represent bad trends in 5
exposures.
6
'lo u can see this, for example, was done some years 7
ago.
People began to focus on what's called special 8
maintenance operations because it was clear -- and in-service that the exposure trends were on 9
inspections the same way 10 an up curve.
And that meant that the regulatory people in 11 NRR could focus their activities in that area, and they did so 12 very successfully, turned that trend around.
13 The present reporting of NRC which is statistical 14 reporting has its primary value, I think in terms of helping l
15 us focus the regulatory a,etivities where they need to be 16 focused.
17 If you went to the next step -- and let me in addition to reporting to.the worker you said 18 hypothesize 19 let's report back to NRC what the individual exposures are, I i
20 don't know quite what you'd do with that information when f
31 you'd get it.
If you were -- I can see how a utility might 23 use it because they could use it to look at very specific 23 activities, changing valves, doing very -- plugging tubes --
24 in terms of their operations.
The design or layout of their 25 facility.
71 1
It's not that evident to me that NRC would have that 2
much value for that information.
So anyway, this proposed 3
package does not change the present reporting.
4 CCMMISSIONER BERNTHAL:
I trust you understand that 5
I wasn't questioning the package.
6 MR. MINOGUE:
Yes, I understand.
7 COMMISSIONER BERNTHAL:
I'm in entire agreement with 8
it I'm using it as an example.
9 MR. MINOGUE:
I do understand that.
I just want to 10 make sure that I'm not misunderstood.
11 MR. DIRCKS:
You may be moving to the next step too, l
12 which would reqdire the annual reporting to the worker.
As l
13 Bob pointed out, it's not in this Part 20 package, but we're 14 going to come to that in the Part 19 revision.
So that will 15 be the next step.
16 And of course, that's the area where EPA has come 17 out with some guidance too that would require -- or would 18 recommend the reporting.
19 COMMISSIONER SERNTHAL:
I'm in full agreement with 20 frequent reporting to workers just like -- call it package 21 labeling.
22 MR. MINOGUE:
What we have planned to do on the 23 timing of that though was to shoot for a target as EPA goes to 24 the President with the guidance.
That the NRC could go out 25 with a proposed revision to Part 19 that would require
t l
72 1
reporting to the workers.
l 2
Well I've talked about the looking at areas The 3
transient worker issue is another issue that largely turns out 4
to be a non-issue, if you look hard at the exposure patterns 5
of transient workers.
And there are other --
6 CHAIRMAN PALLADINO:
Why is that a non-issue?
7 MR. MINOGUE:
There is no demonstrated pattern --
8 CHAIRMAN PALLADINO:
We had quite a bit of 9
Congressional attention ;o that issue.
That was not too long 10 ago-11 MR. MINOGUE:
It's not unheard of for Congress to 12 make major issues out of non-issues 13
[ Laughter.3 14 CHAIRMAN PALLADINO:
I guess I can't deny that 15 Nevertheless, that --
16 COMMISSIONER ROBERTS:
That made the question i
17 worthwhile.
l 18 MR. MINOGUE:
This Commission a number of years ago 19
- it might have become an issue if the Commission hadn't l
l l
2G acted.
But there are rules on the books related to keeping l
l l
21 track of transient workers and making sure that dose l
22 information moves to new employers and so on, that the record 23 would say werks.
Eacause there's no pattern that I'm aware of 24 that shows any statistically important element of higher 25 exposures or larger population exposures among transient
73 1
workers.
2 It's true that many of these people are highly 3
skilled and they do work that inherently involves exposure to 4
relatively levels.
But it's not a situation that's not under 5
control 6
CHAIRMAN PALLADINO:
I didn't say it wasn't under 7
control But I hate to dismiss it as an untrivial item 8
because I think most of these workers are transient.
They go 9
from job to job.
10 MR. MINOGUE:
I'm sorry, sir, I didn't make myself 11 clear.
Action taken by this Commission in a previous 12 incarnation has worked.
I didn't imply -- if the Commission 13 hadn't done what it did I think this could have been a major 14 problem.
15 CHAIRMAN PALLADINO:
Well, what bothered me was you 16 saying, the feeling was that it was a trivial issue.
17 MR. MINOGUE:
No, I think the Commission dealt with 18 it some years ago successfully.
And a lot of people don't 19 perceive that it's been dealt with and that's why you get some 20 political feedback.
21 People are saying you know, if you hadn't done 22 all.those good things that you did you would have a real 23 problem on your hands.
The problem is, you did do all those 24 good things that you did and you don't have a real problem on 25 your hands.
74 i
CHAIRMAN PALLADINO:
But I hate to call it a trivial 2
matter because we may lose sight of the importance of dealing 3
with it 4
MR. MINOGUE:
If I used the word trivial, I withdraw 5
it.
6 MR. GOLLER:
And the reporting requirements that are 7
in the regulations now on transient workers was part of that 8
action.
And the results from that show that these transient 9
workers are not receiving excessive doses.
That the fix was
.0 effective.
That the problem is under control.
L
[
11 MR. MINOGUE:
I'd make a general comment.
I'm 12 really going to focus this primarily in the reactor area.
I 13 think that this agency can take a lot of pride in what has I
14 been done in the last ten years in the reactor area.
Beca..
15 notwithstanding that the plants are getting older, the 16 activity levels are up, there's a lot of maintenance required, i
17 a lot of in-service inspection, a lot of problems, the fact is l
18 that the exposure patterns suggest that the situation is 19 really under control 20 CHAIRMAN PALLADINO:
Okay.
21 MR. MINOGUE:
That's why in talking about this Part 22 20 change when we first began to announce it, I've always said 23 there's no immediate perceived problem here.
We don't have a 24 situation that's not under control We're just trying to 23 bring this regulation in line with current science.
75 1
The next viewgraph talks about a bunch of 2
alternatives that could be considered for expanded 3
CSlide.]
4 MR. GOLLER:
Next one, 27.
5 MR. MINOGUE:
I think we can pass that and go on to 6
the bottom line which is on viewgraph 29.
7 CSlide.)
8 MR. MINOGUE:
Our recommendation is that we let this req'irements.
That we 9
package retain the present reporting u
10 request comments of the public on this whole issue of 11 reporting.
And then as Mr. Dircks said earlier, that we
'1 2 comply with the federal guidance as EPA goes forward with it 13 by amendi'ng the regulations.
But that would be done in Part 14 19, not in Part 20.
15 CCMMISSIONER ROBERTS:
What are the seven 16 categories?
17 MR. GOLLER:
The back-up viewgraph on the categories 18 of NRC licensees submitting annual statist.ical reports.
19 CSlide.]
20 MR. MINOGUE:
Scrry, I had it out when we were 21 there.
Here we go.
Power reactors, fuel fabricators and 22 reprocessors, industrial radiographers, manufacturers of 23 specified quantities of product material, high level waste 24 geologic repositories licensed under Part 60, independent 25 spent fuel storage licensed pursuant to Part 72, and low level
r 76 1
disposal facilities licensed pursuant to Part 61 2
COMMISSIONER ROBERTS:
Thank you.
3 MR. MINOGUE:
That concludes the briefing.
4 CHAIRMAN PALLADINO:
Thank you.
Let me ask first if 5
there are other questions that the commissioners have.
And 6
then I'd like to see what the commissioners feel ought to be 7
the next step.
But first let me see, are there questions that 8
maybe you'd like to address before we address that,one?
9 COMMISSIONER BERNTHAL:
I don't want to prolong the 10 discussion.
Again this is partly for my own education.
I am 11 curious though about this business of our inability as a 12 country apparently to get our arms around some : ort of 13 statistically valid database to get at the issue of the real 14 risk in lower levels.
And I mean lower levels of radiation 15 exposure.
16 And I mentioned in the last meeting, I think, the 17 question of airline personnel and it has come up here again 18 today.
And I went and checked the book on it, and found 19 sources, right or wrong, that suggest that it's more like one 20 R per year for airline personnel And in fact the document 21 that we just got says that in the admittedly high case of 22 someone who flies a lot and flies polar routes you get two R 23 per year maybe.
24 So it clearly is a statistically significant 25 additional exposure though that these people get.
And I still
o 77 1
don't understand why there continues to be the argument that 2
that's not a valid base to use for studying exposures.
I'm 3
surprised.
4 MR. MINOGUE:
The 100 MP per year figure I gave is 5
admittedly about ten years old.
But it was based on an actual l
6 study.
This agency had stewardesses wearing dosimeters.
7 What's changed in ten years, and you're right --
1 8
COMMISSIONER BERNTHAL:
Ten years ago.
I know 9
what's changed.
10 MR. MINOGUE:
Exactly.
It's the long distance 11 aircraft fly at much higher altitudes.
12 COMMISSIONER BERNTHAL:
Right.
13 MR. MINOGUE:
And as you go up in altitude, the 14 exposure rate to cosmic rays goes up very, very 15 significantly.
16 COMMISSIONER BERNTHAL:
That's right.
17 MR. MINOGUEr So I'm sure that people who routinely 18 fly long distance routes or international travel get exposures 19 much higher than 100 MR, the crews.
I'm sure you're right.
20 COMMISSIONER BERNTHAL:
I don't want to pursue 21 the issue.
I still don't understand why we don't deal with 22 that 23 MR. MINOGUE:
Well, we don't regulate cosmic rays.
24 CHAIRMAN PALLADINO:
What would you propose to do 25 with that?
t 78 1
COMMISSIONER BERNTHAL:
Well, I understand that.
2 Why we don't -- not necessarily we, but somebody doesn't make 3
a valiant attempt to determine whether that would form the 4
basis for a s t a t i s t i c a lly 's i gni f i c an t study on low level 5
exposure.
6 MR. MINOGUE:
It might but you'd have to wait.
And 7
the latency period is so long.
8 COMMISSIONER BERNTHAL:
Sure, but we haven't 9
started.
10 MR. MINOGUE:
You'd have to wait 20 or 30 years 1 1' before y'ou'd get your data.
12 CHAIRMAN PALLADINO:
We may get to it.
13 MR. GOLLER:
Commissioner Bernthal, the indications it's not just indications -- the facts are when you look at 14 15 this, the number of people involved and the amount of dose 16
- involved, it's clear that it will not give you statistically 17 meaningful results.
18 MR. MINOGUE:
But I don't think anybody's looked at 19 this question of the air crews.
20 MR. DIRCKS:
It's turnover.
And I happen to know I
21 one study they're doing on air crews, and it shows you the 22 complications, is that they're looking at the air of the air 23 crews, the flight attendants who have to work in an 24 environment where they turn the air over a certain number of 25 times.
The effect of working in compartments where there's
\\
i 79 1
heavy smoking going on for long periods of time. And I know 2
this is one study.
I think the National Academy or somebody 3
is looking into this.
4 It's the number of complicating effects that these 5
people work under.
6-MR. MINOGUE:
In fact that's -- in any specimen that 7
you look at for epidemiological studies, that's the recurring 8
problem.
The incidence rates of these types of caneers is so 9
high from other sources, and the rates are so low, it's really 10 hard to --
11 MR. CUNNINGHAM:
And they you'd have to have a 12 control group that approximates the air group except that they 13 don't fly.
And these people are relatively -- well, they're 14 healthy, they get a lot of physicals, I assume, they're kept 15 healthy.
And there are a lot of complicating factors on that.
16 CHAIRMAN FALLADINO:
Any technical questions?
17 COMMISSIONER ROBERTS:
I've got a quick one for Dick 18 Cunningham.
And I'm not disputing what you say, I just want j
19 to understand the basis for the statement l
l 20 You said that an individual would accept the range 21 of risk of 10 to the
-5 or 10 to the
-8 before they would 22 alter their behavior pattern in the face of some risk.
Where 23 do people come up with numbers like that?
24 MR. CUNNINGHAM:
We come up with them with great 25 difficulty.
But if you look at the things people do in their
30 1
daily lives, drive an automobile, take a walk, go swimming, 2
eat peanut butter, a whole range of things that --
3 CHAIRMAN PALLADINO:
Use electricity.
4 MR. CUNNINGHAM:
-- use electricity that entails 5
some risk on these orders and they never think about them.
6 They would not stop doing them.
It's just a compilation of 7
understanding what the risks are faced in your daily life.
8 CHAIRMAN PALLADINO:
UCLA did quite a bit of work in 9
this ' area.
It started when Chauncey Star was at UCLA, and he 10 did a lot cf statistical studying of risks that people accept 11 in the normal course of business, and tried to infer from that-12 this was a level of risk that people were willing to take 13 without altering their mode of living.
14 Now I'm sur, it's grown quite a bit since I was 15 familiar with it.
16 MR. CUNNINGHAM:
Yes.
17 CHAIRMAN PALLADINO:
But I didn't mean to interfere 18 with your answer.
19 MR. CUNNINGHAM:
Well --
do you 20 CHAIRMAN PALLADINO:
It's still not very 21' have some specifte studies you can point to, I think maybe 22 that would --
23 MR. CUNNINGHAM:
Yes, I can give some specific I
24 studies of reference, 25 CHAIRMAN PALLADINO:
I think that would be helpful l
L
81 1
MR. MINOGUE:
I've seen specific studies also.
2 MR CUNNINGHAM:
There are a lot of --
3 COMMISSIONER ROBERTS:
- Well, I'd like to see them.
4 I'm not questioning the accuracy of the number.
5 MR. CUNNINGHAM:
There's a whole --
6 COMMISSIONER ROBERTS:
I want to understand how this 7
was done.
8 MR. CUNNINGHAM:
Sure.
And this is a whole field 9
growing in itself 10 COMMISSIONER ROBERTS:
I know.
11 MR. CUNNINGHAM:
Risk understanding, risk 12 acceptance, risk perception.
13 COMMISSIONER BERNTHAL:
You could give one very good 14 example and that's the use of seat belts in automobiles, where 15 people have become so numbed by the fact of everyday 16 automobile deaths that surely the risk is far greater than 10 17 to the
-6 or 10 to the
-8.
And yet, an awful lot of people 18 don't take action.
19 CHAIRMAN PALLADINO:
Could you provide all of the 20 commissioners with background information on the basis for 21 that?
22 MR. CUNNINGHAM:
Yes.
23 CHAIRMAN PALLADINO:
I used to be familiar with that 24 general topic, but I've lost touch with it for at least ten 25 years.
o 82 i
Other questions?
2 COMMISSIONER ROBERTS:
No, thank you.
3 CHAIRMAN PALLADINO:
Well, let me ask the 4
commissioners 5
MR. DENTON:
I wanted to make a point or two, 6
Mr. Chairman, just for completeness.
There are a couple of 7
the members in NRR who don't see a need for a new rule.
These 8
individuals feel that the present Part 20 fully satisfy the 9
objectives of ICRP in keeping doses down and point to the 10 complexity that this new rule would bring.
11 We've had a lot of discussions of these kinds of 12 things within the staff and I just wanted to be sure you were 13 aware that they are still going on even today.
For myself, 14 and speaking for NRR, I support adoption of this type rule.
15 think ICRP properly focuses on avoiding unnecessary risk.
16 If you read the ICRP 26 they put the emphasis on 17 justifying any type of risk, applying the ALARA principles, 18 which we've done in reactors, and limits -- setting new limits 19 come last.
And I think in the reactor side, because we've 20 applied the ALARA principle over the years, this new Part 20 21 will have very little impact on the doses that workers in 22 reactors actually achieve.
But if we don't adopt it we're 23 walking away from what has been one of our scientific bases 24 over the years, namely following ICRP.
25 So for a lot of' reasons I recommend we go ahead and
e 1
83 1
adopt this sort of rule even though there are people who doubt 2
that it will actually result immediately in lower doses-The 3
total radiation exposure in the reactor field today is about 4
50,000 rem.
So using the kind of numbers that have been 5
quoted today, you could say that the level of occupational 6
exposure currently occurring results in a random calculation 7
of about five fatal cancers per year.
8 So I think we ought to keep pushing in this area and 9
follow the
- 1. test scientific guidance and try to get the 10 numbers are low as we can.
11 Finally, on a more philosophical vein, there are 12 increasing epidemiological tables that are coming out that are 13 age-specific, which kind of undercut the idea of the limit.
14 And you look in lawsuits, it may be that the limit itself is 15 not going to be as important in the future as the method of 16 compensation.
And you can look at this NIH report for various 17 cancers and various ages and you can determine then if you 18 actually have a cancer, you can retroactively look back in 19 that report and see to what probability there was that any 20 radiation exposure you received might have contributed to that 21 sort of thing.
22 So I think this sort of method is moving in the 23 right direction and I would support adoption of it.
24 CHAIRMAN PALLADINO:
It was my impression from 25 reading the various materials that the present regulations
84 leave a lot to be desired.
And this is a very good i
have 2
opportunity to take advantage of a lot of work and clarify 3
NRC's policies in these. areas.
4 And I do agree that a lot of the issues -- or a 5
number of the issues are highly controversial
'But we have 6
two options.
One we can start to say, well, let's dig in and 7
see where we want to modify it.
The other is to send it out 8
for comment pretty much as it is.
I'd say exactly as it is.
9 And then take advantage of the comments to dig into particular 10 issues that seem to deserve some attention.
11 I had been hoping that today we might take a' poll of 12 the commissioners.
But lacking that, I thought that we might 13 just' hear what individual commissioners' feeling is at this 14 particular point in time and then see if we can't encourage 15 prompt attention to getting notation votes on this.
16 My own feeling would be to send it out for comments 17 as it is.
And I would have no additional areas I'd like to 18 seek comments on, but cthers may have.
19 COMMISSIONER ROBERTS:
I want to see Bill Drexler's 20 latest transmittal which I haven't had a chance to read.
21 MR. DIRCKS:
Is that July 25th?
22 COMMISSIONER ROBERTS:
Yes.
23 MR. DIRCKS:
That really forwarded down the EPA.
24 COMMISSIONER ROBERTS:
Forwarding of the EPA.
I 25 still would like to see that
85 1
CHAIRMAN PALLADINO:
Okay.
But then might you be 2
prepared to 3
COMMISSIONER ROBERTS:
Probably.
give a notation vote on it?
4 CHAIRMAN PALLADINO:
5 COMMISSIONER ZECH:
I want to look into it just a 6
little bit more because of the importance of the issue, and 7
also the lateness of arrival of this last letter.
But I do 8
think that the staff should be commended for a tremendous 9
amount of work over an awful long period of time.
10 And to me the subject is something that merits 11 perhaps updating, bringing up into the year 1985 through
'12 things that have been learned over the years.
I think that 13 probably we could make a more perfect rule by a lot of 14 refinements.
But it does seem to me that on balance that it's 15 an improvement over a system which is already working, as we 16 know.
17 It seems to me it's a sensible thing to put it out.
18 I'd like to make sure in my own mind that I understand all the 19 refinements that have been brought forward recently.
But !
at this time my view would be towards 20 believe that it's 21 essentially putting out the rule as is for comment and perhaps 22 after receiving the comments, then to be able to factor in any 23 revisions that we feel might be necessary before we publish at least at 24 the final rule.
But I think it's appropriate 25 this time, after a little more study on my part, Mr. Chairman,
.~
c
+
86 1
to go ahead and publish the proposed rule.
2 CHAIRMAN PALLADINO:
I was hoping to see us vote 3
this rule out before we all scatter for vacations.
4 COMMISSIONER BERNTHAL:
I'm inclined to get the 5
thing out, too.
I'd like to ask one question.
Almost all of 6
the concerns that I brought up here today cannot be addressed 7
by this rule.
They really involve broader issues, I guess.
8 Let me ask you, the staff, however, the question, of the things we've discussed this morning, are 9
are there 10 there some things that in your judgment would not be commented 11 on or addressed adequately without some further statement in 12 the rule package as it stands?
l 13 Looking over what we discussed here, do you expect to the extent it's possible 14 all of those issues pretty well 15 at all in this rule to be addressed -- do you expect that they 16 would be addressed in the way that we're soliciting comments 17 here?
I'm just asking your view of the discussion this 18 morning, I guess.
19 MR. MINOGUE:
Well, it certainly was our task.
From 20 the beginning of the development of this rule we've tried to 21 solicit a broad base of outside input We've consulted with 22 states, and labor groups, and environmental groups, and 23 industry group.
I think, we think we know what the issues are 24 and we think we know how to present them in a way to get the 25 feedback.
So I really am pretty confident that we'll get the
87 1
broader feedback that we all want, and that people will 2
address these issues.
3 Anyway, we put them all out on the table, what the 4
controversies are.
5 COMMISSIONER BERNTHAL:
I guess my question was, is 6
there anything that we brought up and talked about this 7
morning that you think might not be caught in the net of the 8
package the way it is.
9 MR. DIRCKS:
I think we've picked it all up.
This 10 rule essentially has been in the making now for six years at 11 least.
And there's been a good deal of interaction with the 12 expert groups out there.
So they essentially know what's in 13 here.
They know what the issues are.
We know what they think l
14 the issues are.
And I think you'll get a good response.
l l
15 That's why we're saying 120-day comment period would be i
16 needed.
I l
17 COMMISSIONER BERNTHAL:
- Well, I'm inclined to l
18 can certainly get the rule out, or vote it out by Thursday or 19 whatever the deadline is here.
20 CHAIRMAN PALLADINO:
By when?
21 COMMISSIONER BERNTHAL:
Thursday or whatever our 22 deadline is.
Wednesday, I can do it by tomorrow, I think.
23 CHAIRMAN PALLADINO:
I could do mine by tomorrow.
24 COMMISSIONER BERNTHAL:
I could do it today.
25 CHAIRMAN PALLADINO:
But I don't know
88 1
Commissioner Asselstine won't be back until Thursday.
But 2
could we do it this week?
So that, even if we can't affirm it 3
by the end of this week, can affirm it next week.
4 COMMISSIONER ZECH:
Yes, I could.
5 COMMISSIONER ROBERTS:
Yes.
6 CHAIRMAN PALLADINO; All right Why don't we shoot 7
to try to get it out by Thursday with the hope that we might 8
still be able to affirm it this week.
9 COMMISSIONER ZECH:
Fine, I think we ought to move 10 out 11 CHAIRMAN PALLADINO:
Okay, anything further to come 12 before us?
Well, again I'd like to reiterate words of 13 commendation that you've heard expressed several times.
This 14 has been a real complex undertaking and you are to be 15 commended for the diligence and the state of fruition that 16 you've achieved.
17 So without further ado we wil' stand adjourned.
18 Thank you.
19
[Whereupon, at 11:58 a.m.,
the commission meeting 20 was adjourned.]
21 22 23 24 25
a e
1 CERTIFICATE OF OFFICIAL PEPORTER 2
3 4
5 This is to certify that the attached proceedings 6
before the United States Nuclear Regulatory Commission in the 7
matter of.
Commission Meeting 8
Continuation of 5/15 Briefing on Proposed 9
Name of Proceeding:
Revision of Part 20 (SECY-85-147) to (Public Meeting) 11 Occket No.
12 place: Washington, D. C.
la cate: Tuesday, July 30, 1985 14 15 were held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Pegulatory Commission.
'3 73 T
(Signature)
' '$ gg /gggk
/
(Typed Name of Reporter)
Pamela}Briggle 20 21 22 23 Ann Riley & Associates, Ltd.
24 25
FOLLOW-ON BRIEFlf0 FOR Tile C0FNISSION ON PROFOSED IBISION OF 10 CFR PART 20 "STAf0ARDS FOR PROTECTION AGAINST RADIATION" JtLY 30, 1985
TOPICS TO I1E A10lESSED PACKGROUND ItF0fEATION ON. RADIOLOGICAL PROTECTION PRINCIPLES PROJECTION OF AN B4BRY0/FETllS DE MININIS LEVELS REf0RTING OF WDRKER DOSES 9
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BACKGROUND INFORMATION ON RADIOLOGICAL PROTECTION PRINCIPLES O
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CONSEQUENCES OF LOW-LEVEL EXPOSURE 4
50 REM e
DOSES I
e STOCnASTIC (RANDOM) EFFECTS l
INCIDENCE PROPORTIONAL TO DOSE (+ 10-4/ REM)
CHANGES IN CELLULAR CHEMISTRY IN SMALL NUMBERS OF CELLS CELLS DIE - NO HEALTH EFFECT CELL REPRODUCES ABNORMALLY e
ABNORMAL CELL REPRODUCTION CAN RESULT IN:
CANCER j
6ENETIC DEFECTS S
llEALTH EFFECTS ARE LATENT i
CANCER 5 To 30 YEARS POST EXPOSURE l
6ENETIC DEFECTS - FUTURE GENERATIONS i
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RADIOSENSITIVITY e
Nor ALL CELLS EQUALLY RAD 10 SENSITIVE e
GENERALLY, THE MORE RADIOSENSITIVE CELLS ARE ONES THAT MULTIPLY RAPIDLY OR HAVE LARGE NUCLEIC ACID CONTENT RADIOSENSITIVE IISSUES INCLUDE BONE MARROW GONADS INSENSITIVE IISSUES INCLUDE CENTRAL NERVOUS SYSTEM SKIN.
6
RADI0 BIOLOGY OF PRENATAL EXPOSURE e
UNFERTILIZED EGG CELLS HAVE LOW RAD 10 SENSITIVITY e
HIGn RADIOSENSITIVITY DURING PERIOD OF rapid CELL DIVISION PERIOD OF 6REATEST RISK PER UNIT DOSE -0RGAN0 GENESIS (8-15 WEEKS) e 7
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REV1 SED 10 CFR PART 20 CALCULATION OF INTERNAL EXPOSURE INCLUDES
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e DISTRIBUTION AMONG ORGANS RATHER THAN SINGLE CRITICAL ORGAN e
INCLUDES EXPOSURE OF ORGANS DuE TO DEPOSITION OF MATERIAL IN OTHER PARTS OF Tile BODY e
UPDATED RADIONUCLIDE DISTRIBUTION AND RETENTION MODELs.
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EFFECTIVE DOSE Eo'UIVALENT e
EXPOSURE OF ORGAN 6IVES RISK OF EFFECT (CANCER) e FOR A 6IVEN EXPOSURE, Tile PROBABILITY OF EFFECT DEPENDS UPON THE SENSITIVITY OF Tile ORGAN e
COMMON DENOMINATOR IS RISK OF EFFECT e
EFFECTIVE DOSE [QUIVALENT OF 1 Ren is Tiie DOSE NECESSARY IN AN ORGAN TO PRODUCE A RISK [00AL TO Tile RISK OF EFFEcT FR6M 1 rem OF EXTERNAL, WiiOLE-BODY RADIATION.
9
COLLET.IVE DOSE
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FOR PURPOSES OF RADIATION PROTECTION, EF,FECTS ARE ASSUMED TO BE llNEARLY o
PROPORTIONAL TO EXPOSURE IN STOCilASTIC RANGE e
SUMS INDIVIDUAL DOSES IN POPULATIONS TO DETERMINE RISK OF LATENT EFFECT IN POPULATION ASSUMES RISK OF LATENT EFFECT IN IllE POPULATION INDEPENDENT OF DOSE DISTRIBUTION, e
PROVIDED DOSES TO INDIVIDUALS ARE WITillN LIMITS IN IllEORY, COLLECTIVE DOSE ASSESSMENT INCLUDES ALL DOSES, BOTli PRESENT AND e
Future, REGARDLESS OF DISTRiauriON IN POPULATION AND INSIGNIFICANCE OF INDIVIDUAL DOSE IN PRACTICE, ACCURACY AND UTILITY OF COLLECTIVE DOSE ASSESSMENT llMITED BY LACK OF e
ADEQUATE DATA, E.G.,
60SE DISTRIBUTION AND PATilWAY MODELS SIZE OF FUTURE POPULATIONS POPULATION SilIFTS WITil RESPECT TO LOCATION OF SOURCE FUTURE EVENTS WillCil MIGitT AFFECT DOSE OR CONSEQUENCE
PROTECTION OF AN FJ11RYO/ FETUS ISSUE:
PIOTECTION OF AN EMBRYO / FETUS AGAINST OCCUPATIONAL IMDIATION EXPOSulE OF PREGNANT WORKER.
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4 EPA Pfl0 POSED FEDERAL GilDANCE ON RADIATION Pf<0TECT10N FOR OCCUPATIONAL EXPOSilRE DEVELOPED BY INTERAGENCY WORK GROUP i
INCLUDES GUIDANCE ON PROJECTION OF AN EITRYO/
FETUS AND OTilER ISSIES IN 10 CFR PART 20 GUIDANCE SulfillTED TO AFFECTU) FEIERAL AGENCIES FOR CONCURRENCE MARCil 25, 1985.
NRC LETTER TO EPA Jl#E 7,1985 CONCURRED, IE0VllED C0ftENTS AND REQUESTED CLARIFICATION ON SPECIFIC t
ISSLES.
C0f1FLICT IEINEEN DOE a lillS ON AN0lllER SUBJECT IN GillDANCE MAY DELAY SUBMITTAL TO PfESIDENT 12
FAJOR FACTORS CONSIDERED BY EPA INTERAGENCY WORK GROUP RELATIVE TO PROJECTION OF AN EFERY0/ FETUS SCIENTIFIC DATA ON lilGIER RADIATION RISKS TO AN EftRY0/ FETUS REC 0Ff04DATIONS OF MAJOR RADIATION PROJECTION ADVISORY ORGANIZATIONS (ICRP a NCRP)
EfPLOYfO(T RIGITS a OPPORTUNITIES FOR h001 INVASION OF PRIVACY CONSIDERATIONS T.
13
[MJOR ALTERNATIVES CONSIDEED BY EPA INTERAGENCY WORK GROUP FOR PROTECTION OF AN EMBRYO / FETUS INF0ffED CONSENT
- DECISION FOR PROTECTION ENTIELY BY WOFMN LOWER DOSE LIMIT FOR WOKN SELF-DECLARED TO E PEGtMNT
- SO K POTENTIAL FOR LOSS OF JOB OPPORTUNilY
- RETAINS ELI K NT OF DECISION MAKING BY WOMAN LOWER DOSE LIMIT FOR WOE N KNOWN TO BE PREGNANT
- LOSS OF JOB OPPORTUNITY - INVASION OF PRIVACY - POTENTIAL OVEREXPOSUE IN FIRST STAGES OF PREGNANCY LOWER DOSE LIMIT FOR FERlILE WOWR
- LOSS OF JOB OPIORTUNilY
- INVASION OF PRIVACY
- ASSURES FETAL PROJECTION TilROUGDIT PEGNANCY LOWER DOSE LIMIT FOR ALL WOEN OF CllllD BEARING AGE
- LOSS OF JOB OPPORTUNITY
- ASSUES FETAL PROTECTION THROUGKXJT PEGNANCY LOWER DOSE LIMIT FOR ALL h0RKERS
- ASSURES UNIF0ffl JOB IMPACT ON ALL WORl(ERS 14
EPA ESPONSE TO NRC EQUEST FOR CLARIFICATION SPECIFIC EXPOSUE LIMIT OF 0.5 EM TO EMBRYO / FETUS DURING ENTIE PREGNANCY OF A DECLA[D PREGNANT WORVER DOSE LIMIT OF FOR AN EltRYO/ FETUS AND SOCIAL-ECONOMIC CONSIDERATIONS ARE TO E fU INDEPENDENTLY.
- DOSE LIMIT TO DE ENFORCED BY NRC
- SOCIAL-ECONOMIC CONSIDERATIONS TO E ADDESSED BY OTIER ENTITIES
- TllE FEMALE WORKER AFFECTED WILL E TIE SOLE SOURCE FOR " DECLARATION" 0F PREGNANCY.
SMALL ADDITIONAL EXPOSUE PERMITTED IF EXPOSUE TO ENRY0/ FETUS HAS ALEADY EXCEEDED 0.5 REM LIMIT WlEN WORKER DECLAES PECMANCY.
- TIE PROPOSED FEDERAL GUIDELINES WILL E REVISED TO PROVIDE TilESE F0E EXPLICIT EC0ftENDATIONS.
15
STAFF [C01ENDATIONS REVISED 10 CFR PART 20 Sl00LD BE FULLY CONSISTENT Willi EPA PROPOSED FEDERAL GulDANCE ON OCCUPAT10l!AL EXPOSulE.
PROPOSED RULE S10Ull):
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- ESTAPLISil A DOSE LIMIT OF 0.5 REM TO AN EltRYO/ FETUS OF A SELF-DECLAfG PREGNANT WORKER.
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- ALLOW AN ADDITIONAL 0.(E REM TO AN EtERYO/FEIUS IF TIE 0.5 REM LlHIT llAS BEEN EXCEEDED BEFORE lilE DECLARATION OF PREGNANCY l
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DE MINIMIS LEVELS I
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1.
SIDJLD CALCULATIONAL " CUT 0FF" LEVEL FOR COLLECTIVE DOSE ASSESSENTS BE l
ESTABLISilED?
2.
IF ESTABLISIED, AT WilAT LEVEL S101LD TIE CIII0FF IE SET?
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USE OF DE MINIMIS DOSE CM CEPT
- EfERALLY, DE MINIMIS DOSE PEANS A DOSE WillCll llAS AN ATTENDART RISK SO LOW 111AT IT DOES NOT WARRANT EGULATORY ATTENTION.
- TIERE AE MAf# POTENTIAL APPLICATIONS OF DE MINIMIS CONCEPT.
- IEITIER EXISTING t0R PH0 POSED FEDERAL GUIDANCE INCLUDES ANY APPLICATION OF DE MINIPUS CONCEPT.
DE MINIMIS DOSE CONCEPT IN Pf0 POSED 10 CFR PART 20 REVISION IS VERY LIMITED -
ONLY FOR CALCULATIONAL " CUTOFF" FOR COLLECTIVE DOSE ASSESS E NTS.
i COLLECTIVE DOSE ASSESSFENIS ARE A MAJOR CONSIDERATION IN DECISIONS AD001:
- FJLANCE PElkWi ItalVIDUAL DOSE AND POPULATION DOSE IN DETEft11NING ALARA.
- CIDICES NUXi AVAILAPLE OPTIONS FOR PROVIDING Pf.DIATION Pf0TECTION.
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LIMITATIONS ON CALCILATION OF COLLECTIVE DOSE ASSESSKMTS COLLECTIVE DOSE ASSESSKNTS ALREADY BEING LIMITED IN DIFFEKNT WAYS:
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- 50 MILES (10 CFR PART 50, APPENDIX I) 10,000 YEARS (EPA RULB4AKING) j
- NORTil AKRICAN POPULATION (NRC URANIlN MILL TAILINGS GEIS).,
REGARDLESS OF lEril00, EA01 INVOLVES DELETING SOK FORTION OF COLLECTIVE DOSE Flul ASSESSKNT CALCULATIONAL " CUT 0FF" DOSE FOR COLLECTIVE DOSE ASSESSKNT IN PROPOSED lEVISI0ll:
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- 1 MRBi K R YEAR TO If0lVIDUAL I
- ASSOCIATED WITil POTENTIAL INDIVIDUAL RISK OF ABOUT 10-7 SERIOUS IIEALTil EFFECTS E i
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Wily ESTAPLISil CALCULATIONAL CtROFF DOSE?
1 WILL PROVIDE A CONSISTEt6 BASIS FOR LIMITING TIE EXTENT OF ASSESSKNT OF COLLECTIVE DOSES.
WILL.Pf}UVE SlRECTIVITY OF lMNOWS Af0 UNCERTAltlTIES LEADING TO 00TENTIAILY INCORRELT Jt0GEENTS:
- (KERTAINTIES ASSOCIATED WITil DISTANCES FAR FROM TlE SOUFCE
- lNCERTAINilES ASSOCIATO WITil LONG PERIODS OF TIK i
- VANISilINGLY SMALL RISKS TO TIE EXPOSED INDIVIDUAL, I.E., DE MINIMIS.
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WILL SIGNIFICANTLY REIKE RESOURCE C&HITENTS.
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APitICATIfW 0F T MINIf1IS CONCEPT TO IlUlVIDilALS WOULD ESTAPLISil AffAJAL DOSE LEVEL SO SMALL TilAT IiOIVIIX1ALS lJSUALLY WOULD TOT CONSIER TIE RISK IN ARRIVING AT DECISI0tS EGARDING TIEIR ACTI0tS.
APPLICATIONS WOULD BE FUDI BROADER 111AT CALClLATIONAL "CLITOFF" NO REGlLATORY ACTIONS WOULD E IfiY) SED FOR IYJSES ELOW Tills LENEL CDST REDUCTIONS WOULD E APPRECIABLE (E.G., RAWASTE DISPOSAL, EFFLlM Pl10CESSIPL).
WAS C04SIERED DURIt0 DEVEL0fENT OF PR0lY) SED RULE.
COULD [SULT IN:
UNAPITOVED-INCORFORATION OF RADI0 ACTIVE MAlERIALS INTO CONSIKR IH01)lfIS l
RELEASE OF VERY LW-LEVEL WASTE STEAFE WIT 110lff EVALUATIGl l
l RAISING LEVELS, AS IN NIP TE0f4ICAL SECIFICATIONS, AT WilI01 CERTAIN CONIl0LS OR EOUlffDIT FUST E I! STALLED OR OPERATED.
SUPftEENTAL IIFORMTI0fl 0F PROPOSED RULE DISCUSSES APO SPECIFICALLY fifAESTS CGtOflS.
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STAFF EGMD0ATIONS i
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- ESTABLISil A CUT 0FF LEVEL OF 1 lifM/YR ON It0lVIDUAL DOSES TO E USED IN TIE CALCULATION OF COLLECTIVE DOSE ESTIMATES FOR REG PURIUSES.
- SKCIFICALLY E0 TEST 12LIC C0WENT ON Tills ISSLE Af0 ON A DE MINIMIS LEVEL FOR IltIVIDUALS.
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HESEffT WORKER DOSE EIMTIl0 EQJIIHEIS B
Aff0AL STATISTICAL StMMRY Kf0RTS-Fim 7 CATEGORIES OF LICENSEES LICENSEE IENTIFICATION OftY fDIER & WORKEIG E&IVING DOSES WIlllIN SECIFIED DOSE RANGES B
EIMTS m TOTAL DOSE E&IVED BY WOIEERS WD TEfEINATED DFLOWENT-FROM SAFE 7 CATEGORIES OF LICENSEES.
LIENSEE IDENTIFICATION WOI4ER IDENTIFICATION (NAPE, SS 10., BIRTll DATE)
KRIOD OF Erft0WENT MAGNITLDE APD TYPE OF RADIATION DOSE 3
EfMTS ON DOSES E&IVED BY WORIIRS WEN LIMITS Aff EXCEEIED
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LICENSEE IDENTIFICATIGl WORIIR IDENTIFICATIle 1
TI E & EXPOSURE liAGNITIIE AIO TYE OF RADIATION DOSE In EfMT TO WORIER Fim ANY LICENSEE ITM EDEST Fim WORKER FAGNIll10E Al0 TYK OF RADIATION DOSE E&IVED IN YEAR B
UP( ElWI TO W0 iter WEEVER IEORMATION EfMTED TO NRC BY NAED It0lVIDUAL 24
t STAFF USES OF EPORTED RADIATION EXPOSURE DATA RE DATA OBTAIED FI(M PESENT EFORTING EQUIREMMS PEIMIT ESTIMATES OF:
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SIZE OF RADIATlal htWFORCE.
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0 P'AGilTl0E OF #NML COLLECTIVE DOSE.
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0 TEMIS T EXFOSIEES CGPARIS0N & DATA 11Y TYPE OF LIENSEE, AM) BY LICENSEE WillllN EA01 TYPE l
DOSE DISTRIIllIl0N VARIATION Willi TIE.
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0 TP.ANSIENT WOffER DOSES.
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1 EXAPRES OF SPECIFIC llSES OF REPORTED EXF0SURE DATA i
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K)NITORING OF TRANSIENT WORKER OVEEXPOSLES i
IM)IVIDUAL WORKING AT 11LTIFtE PLANTS DURING A OUARTER IS C& MIN i
i 00EXPOSWES ARE 110M 10 E EXIFOELY RARE i
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O EXTENT OF AllE0l#E fdDI0 ACTIVITY PROBL&l FOR MP'S WOF$3S 4
)
NO DVEREXf0SWES REFORTED TO DATE 1
E OF llE EPORTED KASUEIDif RESULTS FOR INTERNALLY DEPOSIlED RADIDACTIVilY AFE LESS IllAT 5 0F "fUtlISSIBLE" (11ANTITY TIEEFOIE FEW NRC IESOURCES EED E O(PEtKD FOR PROTECTION IN Tills Alfa l
)
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ALTERNATIVES O
C0fRI?UE PfESEPH lEWIIDORS At#UAL STATISTICAL SlWARY REf0RIS 10 NRC FID17 LIENSEE CATE00 RIES TEP!ilfiATION EPORTS TO NRC FID17 LICENSEE CATEGORIES (COPY 10 WORER)
O EXPAt0 PESEIR EOUIIDEfRS TO INCLLDE ALL LICENSEES O
TEOUIE Afid]AL EXPOSUPf IUORTS FOR EA01 INDIVIDUAL WORIER TO TlE WORKER FfDl:
7 LICENSEE CATEGORIES ALI. LICE?EEES 0
EWIE Att0AL EXPOSUE EPORTS FOR EA01 ItUlVIDUAL WORKER TO TIE WORVER Ato NRC FROM:
7 LIENSEE CATEGORIES ALL LICEf6EES 0
TliilfE (f EWIREKfR FOR All0AL EIORTS OF NAKD INDIVIDUAL WORKER:
IUCLLDE IN FINAL RULE (PART 20)
REVISE PART 19 SEPARATELY ( IF ILPORT ONLY TO WORKER IS EQllED PAR f0T IN PART 20).
27
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l REI G TIf0 0F WORKFR DOSES CONSII G ATIONS i
O PKSDR EFGTIl0 EalllODffS f50VII INCfMLETE IRTA, E.G.,:
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NO ROUTIE OCClFATIOPRL EXFOSUE Ilf0HPiATION IS KIMTED IN mal # NRC LICENSEES, INCLIEING EDICAL INSTITlIIIONS.
(EDICAL W0ltERS ECEIVE AHOUT IRLF 0F TIE AfMRL COLLECTIVE OCClFATIONAL DOSE).
NO ROUTIE OCOPATIONAL EXFOSLE Iff0lMTION IS EPORTED BY TIE AGEEENT STATE LICENSEES.
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(ACEEKPff STATES EGULATE LICENSEES IRVING ABOUT 200,000 0F llE 500,000 WOIERS MONITDfE).
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DATA SAPFLE FOR IfffEf<NAL EXFOSURES TO ALPIM EMITTERS T00 SMALL Al0 LNTIKLY FM STAFF ECDS.
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O TlE EPA IS000 SED FEDERAL WIDANCE W0llD K0UIE EPPLOYERS TO EPORT W0fER AlEAL DOSES TO TIE W0lER l
WITil NO EQUIIDENT ON EPORTING TO ANY FEDERAL A6ENCY.
EPA IS000 SED FDHAL WIDAfEE PiAY NOT K FIPRLIZED FOR S&E TIE.
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l STAFF RE00PMM)ATIONS O
CONTIfE TIE PESENT EQUIRDOff FOR AfMJAL STATISTICAL SlWARY EPORTS AND TEININATION REFORTS FROM 7 CATEGORIES OF LICENSEES WOSE EWLOYEES AE CONSIDEED TO ACCEPT TE HIGIEST RISKS.
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SECIFICALLY E00EST COPMNTS ON TllIS ISSUE.
O C0tTtY Willi EW F3f_RAL GJIDANCE (AfMJAL EXPOSUE EPORT TO EA01 WOIER) BY AEM)ING fEGULATIfflS AFIER MW FEDERAL GJIDATE IS ISSLED.
29
YkkhhY hYt hYkhYhkkt0hkkkkkkkghhkkg0g0g0hghghghg0kg(g(p0ghhg0fh 12/82 TRAtEMITIAL 'IO:
ntv,==nt Control Desk, 016 Phillips Ij ADVAN3D (X)PY 'IO: /
/
Ihe Public Docunent Ibcm DME:
[f p
f cc: OPS File
[
C&R (Natalie) ll:iP Attached are copies of a (bmnission meeting transcript (s) and related meeting i
h _==nt(s).
'Ihey are being forwarded for entry on the Daily Accession List i
and placanent in the Public Doctanent Ibcm. No other distribution is requested
.L cr required. Dcisting DCS identification ntsnbers are listed on the individual h = nts wherever known.
Meeting
Title:
[+<< L M h/4' /do M,/ m MN_
[Lu.mA4_) O h
Meeting Date:
7/3 o /Pr Open I Closed l3 ll DCS Copies l3 (1 of each checked) l:
Itan
Description:
Copies 3
Advanced Original May Duplicate lj To PDR Doctrnent be Dup
- Copy
- l3l 1.
TRANSCRIPT 1
1
'3 When checked, DCS should send a j
oopy of this transcript to the g
LPDR for:
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