ML20137E161
| ML20137E161 | |
| Person / Time | |
|---|---|
| Issue date: | 02/13/1997 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20137D869 | List: |
| References | |
| SECY-95-249-C, SECY-96-110-C, NUDOCS 9703270080 | |
| Download: ML20137E161 (2) | |
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NOTATION V0TE RESPONSE SHEET i
T0:
John C. Hoyle, Secretary l
FROM:
COMMISSIONER MCGAFFIGAN i
j
SUBJECT:
SECY-%-110 - COMPLETION OF RESPONSE TO THE STAFF REQUIREMENTS HEMORANDUM, FOR SECY l 249, ON RISK HARMONIZATION WHITE PAPER AND 1
RECOMMENDATIONS BY THE INTERAGENCY STEERING COMITTEE ON RADIATION STANDARDS l
Approved x } dDisapproved Abstain 4
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Not Participating Request Discussion yM COMMENTS:
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Release Vote
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DATE El8 2?88R8 E 8g20 l
CORRESPONDENCE PDR Withhold vote
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Entered on "AS" Yes V
No Fi?o37700Co
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Commissioner McGaffican's Comments on SECY-96-110 i
I am approving the staff proposal with regard to how to complete action on the l
Risk Harmonization White Paper.
However. I want to note a couple of comments on the attachments to this SECY paper. could have been more direct in discussing the inconsistencies in example,proach to limiting risks from exposure to ionizing radiation.
EPA's ap For l
a dose limit for radon (e.g.
200 millirem / year) might have been included in the sentence beginning " Radon is given special treatment..."
Further, no mention is made of EPA's disinterest thus far in dealing with NORM in such settings as coal ash, where exposures may be far higher than in currently regulated activities.
In general, we may want to be less diplomatic in pointing out EPA's inconsistencies in the future.
4 Second. the statement in Attachment 3's Summary that "it is difficult to draw conclusions about the relative magnitudes of chemical background risk versus 4
radiation background risk because chemical risk assessments are so much more uncertain than radiation risk assessments" may be illusory. As the body of the 3 aper points out. radiation risk assessments also have huge uncertainties in t1e range in which the linear no-threshold hvoothesis is applied for regulatory purposes.
The 100 mrem / year standard is an extremely conservative extrapolation from the data on the atomic bomb survivors.
Extrapolating another factor of 100 to the 1 mrem / year level, which has sometimes been done, for instance in the recent electric arc furnace baghouse dust case (see COMSECY-97-002), brings conservatism to absurd heights. As the paper later points out, it is possible that at low doses radiation has beneficial effects larger than detrimental effects. Therefore, when we do not even know whether radiation is a benefit or a detriment in these low dose ranges, radiation risk assessments may be as problematic as chemical risk assessments.
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UNITED STATES o,,
l NUCLEAR REGULATORY COMMISSION E
a WASHINGTON,0.C. 20555-0001 SECRETARY l
f MEMORANDUM TO:
L. Joseph Callan i
Exec
-ive D* rector for Operations h
FROM:
John C.
Ho e,
Secretary
SUBJECT:
STAFF REQUIREMENTS - SECY-96-110 - COMPLETION OF RESPONSE TO THE STAFF REQUIREMENTS MEMORANDUM, FOR SECY-95-249, ON RISK HARMONIZATION WHITE PAPER AND RECOMMENDATIONS BY THE INTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS The Commission has approved the staff's recommendation not to amend the White Paper to include a discussion about the application of EPA's.10" to 10 risk limits.
The Commission has approved distribution of' Attachment 1 to the other ISCORS participants and other interested parties.
I The Commission requests that when reporting on matters related to EPA regulation of ionizing radiation, the staff provide a full and direct discussion of the technical issues and policy implications.
The Commission notes that Attachment 1 could have been clearer and more direct in discussing EPA's approach to limiting risk from exposure to ionizing radiation.
For example, it might have been useful to note EPA's annual limit for radon (200 millirem) i and EPA's general disinterest to date in dealing with NORM in such settings as coal ash.
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SECY NOTE:
THIS SRM, SECY-96-110, AND THE COMMISSION VOTING RECORD CONTAINING THE VOTE SHEETS OF ALL COMMISSIONERS WILL BE MADE PUBLICLY AVAILABLE 5 l
WORKING DAYS FROM THE DATE OF THIS SRM.
YO f?
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. I cc:
CPairman Jackson Cormissioner Rogers Commissioner Dicus Commissioner Diaz Commissioner McGaffigan OGC OCA OIG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)
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