ML20147D173
| ML20147D173 | |
| Person / Time | |
|---|---|
| Issue date: | 09/05/1978 |
| From: | NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | NRC OFFICE OF STANDARDS DEVELOPMENT |
| Shared Package | |
| ML20147D168 | List: |
| References | |
| RULE-PRM-20-6, TASK-OH-506-1, TASK-OS NUDOCS 7812190078 | |
| Download: ML20147D173 (10) | |
Text
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O MINUTES OF THE MEETING 0F THE INTERAGENCY POLICY COMMITTEE Held Tuesday, September 5,1978, in Room C-229, Radiation Physics Building, NBS.
Members present:
Bob Alexander, NRC; Luis Garcia, EPA; Joe Gitlin, BRH; Jim Leiss, NBS; Vandy Miller, OSG; Ed Vallario, DOE Consultants present:
Bill Spell, Louisiana Department of National Resources Claire Palmiter, consultant, NRC Alternate present:
Don Thompson, BRH Also present:
Greta Ehrlich, NBS 1.
Acceptance of minutes of last meeting Question and comment by Gitlin:
Re page 1 - Could Alexander send out the list of the 18 Groups that did not respond to the invitation to participate in the Pilot Study? Alexander will do it.
Re page 2 - Inasmuch as none of the Naval Shipyards had volunteered, Gitlin evidently was instrumental in inducing the Charleston Naval Shipyard to participate.
Alexander then wanted to know by whom the Nuclear Navy is represented on the Policy Committee. Miller said he was their representative.
Vallario pointed out that the Navy did not participate because the invitations were handled not through their machine, but in a " low key", through Plato.
If participation from Rickover's j
people were required, it would have to be handled according to protocol.
7 s/4 M G @ 7 8' The minutes then were accepted in substance, with the understanding that the small errors still remaining (such as, Vallario's wrongly-stated affiliation) could be corrected without a further discussion.
Alexander then mentioned in passing that he knew of one laboratory definitely interested in the job of a testing laboratory, namely, the University of Michigan School of Public Health.
2.
Regarding Comments on Timing of NRC Announcement.
Leiss asked Alexander for comments. Alexander said that he liked the way it was handled.
It gave him ample opportunity to comment on the draft of the Leiss synopsis of the committee recommendations before the letter went out.
He plans to incorporate the letter in the staff paper.
The recommendations will be useful, since they will pave the way for early discussions on the staff paper.
Leiss wanted to be sure that attention be paid to the last coment, i.e., that if there are substantive reasons why the Standard is not acceptable there will be a chance for coments.
Alexander plans to place this statement close to the beginning of the Federal Register notice.
Palmiter, who wondered who had been against proceeding with the proposed rule making in such a way that the coment period would end before the completion of the pilot study, was informed that Lee was, and others (such as Garcia) also were rather cautious. Leiss summarized the majority Committee opinion tha't the enormous present public concern about personnel dosimetry made it imperative to go ahead now rather than in, say, two years.
Gitlin wondered whether this caused a protocol problem for NRC.
He just wants to be sure that everybody agrees with the importance of the last paragraph of the letter, i.e., that there should be a chance for later modifications.
Garcia added that the ties with the HPSSC Draft Standard are critical; but that the Standard con'tained certain arbitrary assumptions regarding the conversion
.- from what is measured to dose equivalent. Alexander pointed out that the NRC is anxious to have an opportunity to show that they are doing whatever is possible to save tir$e.
A discussion then ensued on the conversion from exposure to the dose-equivalent index for low-energy photons. Alexander reported on the Battelle-Northwest proposal for a study by Bill Bartlett et al, resulting in an experimental detennination of the conversion factors by means of extrapolation-chamber measurements.
NRC plans to support this work.
When Garcia mentioned that he wondered why NBS was not doing this work, Ehrlich said that although NBS was very short in staff, an attempt is being made here to carry out an experimental determination by a different method. Alexander and Garcia then wondered what would happen if the experiments did not bear out the theoretical
~
conversion factors use'd in the Standard.
Leiss sees things in a different complexion: There are two issues involved--measurement quality and data interpretation.
Once one is sure that measurement results are obtained in an adequate way, are properly documented, and interpreted uniformly, one may proceed to examine the scientific background for the criteria.
Although, as Palmiter pointed out, the ICRP may approve data from any source, and the federal agencies are not obligated to use ICRP data, the concensus after a lengthly discussion was that, for the sake of stability, where ICRP data are available, they should be used in the Standard.
The data presently in the Standard should be kept until the ICRP comes out with new recommendations.
Vallario pointed out that it was ANSI protocol to follow ICRP recommendations.
Bypassing ICRP would cause major problems with ANSI.
Ehrlich added that the NCRP Ad Hoc Committee on Radiation Measurements that will submit a report to the Council in mid September has given a high priority to the topic, I
4 Instrumentation and Methods for the Determination of the Restricted Index Quantities, which is to address itself specifically to the question of the determination of the index quantities from what is actually measured. Also, ICRP Committee 3 (C. Meinhold, Chairman) is in the process of forming a working party concerned with the use of the restricted index quantities (and related quantities) in protection measurements.
It was decided that, inasmuch as the Draft Standard was to be reconsidered in one year, it would be important to impress upon the NCRP the urgency of action concerning the quantities to be used in protection measurements.
Ehrlich agreed to convey this thought to the chairman of the NCRP Ad Hoc Committee, of which she is a member.
3.
Status of Draft Standard Vallario reported that the Draft Standard was published by ANSI in July 1978 L
- as N 13.11, on a trial use and comment basis, for reassessment after one year.
Only after the reassessment will it become a Standard with a five-year review period.
l l
He noted that the Surface-Contamination Standard, N13.12, also came out as a Draft 1
Standard.
So far, he has received no reaction to N13.11.
Eventually, as Gitlin and Spell pointed out later, most technical comments to the Draft Standard will come as a result of its being reviewed in connection with the Pilot Study.
Leiss asked Ehrlich to have NBS obtain copies of N13.ll for all participants in the Policy Committee.
4.
Confidentiality of Test Results and Progress of the Pilot Study.
- Office, Alexander reported that the NRC of the Executive Legal Director feels that there g
would be no problem if NRC received a request under the Freedom-Of-Information Act for Pilot-Test results obtained on specific processors in spite of the commitment
to all processors that the test results would be confidential.
The legal office feels that as long as the NRC contract with the University of Michigan states that the University is not to reveal processor identification to the NRC, NRC is not required to give it out.
The NRC recently modified the wording of the contract with t University of Michigan to spell out specifically that the University was not going to give to the NRC the key to their code.
Upon an inquiry from Spell, Alexander confirmed that this would hold for the results of the Pilot Study, both during and after the Study.
Leiss added that the matter may be handled differently for later tests.
Gitlin wondered whether the NRC had obtained a legal brief to ensure that the legal council be held to its decision.
Alexander and Palmiter are not aware of there having been issued such a brief.
Leiss suggested that Alexander ask for a memorandum from the NRC Legal Office.
Alexander further reported that the Pilot Study was progressing on schedule.
He recently asked Plato to include sample results in the progress reports.
(Copies of these reports were distributed to the Policy Committee.) Also, he asked them to collect information on how the participants account for actual background.
Inasmuch as there will be no re-testing of poor performers during the Pilot Study (everybody w!'.1 be tested twice), Plato is not analyzing all of the results in detail on a current basis. At present, all persons involved are busy with the irradiations.
They will have six months for data analysis after the completion of the two rounds of irradiations.
Gitlin suggested that his people could held design an automated system for this analysis.
5.
NRC Progress on Proposed Rule Making Alexander reported that Palmiter was given the assignment to (1) develop a value, impact analysis and write a value-impact statement, and (2) prepare
a discussion paper, as the basis for an eventual staff paper.
This discussion paper will be available to the Policy Committee.
Palmiter expressed the opinion l
that the decision regarding distribution of drafts should be made by the NRC staff rather than by him.
It was the consensus of the committee that it is important to have an early draft in the hands of Leiss, for distribution to the Policy Committee.
At the time of distribution, Leiss will inform the members whether or not the particular draft was for distribution via the Committee members for official response from their respective agencies. Official agency response probably will be in order at the time copies are being sent via the NRC to the Agreement States for comment.
The NRC effort is to consist of several separate parts:
There will be the regulation, i.e., the document that goes.into Part 20.
Nothing will be said there about the support of the testing laboratory. The Standard either will be issued as a regulatory guide or adopted in Part 20 by reference.
The NRC staff's position will be spelled out in a u....
staff paper which will give the background and the different alternative approaches, probably with a slant toward a particular one.
Palmiter then reported that what he has been doing so far was to get a feel for the financial bounds for a testing program through discussions with several of the parties concerned.
For this purpose, he spent time in the NRC Cost-Benefit Section.
The trouble there is that this Section has no expertise in personnel dosimetry.
He further spent time with NRC Inspection and Enforcement (B. Weiss) and plans to spend some time also with several of the members of the Policy Committee.
Examples of specific questions to be answered are:
How many ' testing laboratories will be viable? How is a testing laboratory to be established?
(Internally, within the NRC? By the AAPM? Leave it independent--i.e., have Battelle-Northwest, the University of Michigan, or 1daho Falls establish it?) He has 35 pages of notes as the basis for writing a
7 first draf t in the next two weeks.
It was decided to schedule the next meeting of the Policy Committee for a time when there will be a draft in the hands of its members.
Leiss suggested that Palmiter develop a decision chart (not a PERT chart, Gitlin added) on the questions to be answered, e.g., the number of testing laboratories, the source of support, etc.
l 6.
Rcport from the States.
After transmitting Lloyd's regrets, Spell gave a brief background on his own former involvement in the problems of personnel dosimetry, e.g., finding out t' hat two processors may come up with widely different results derived from different dosimeters worn simultaneously by the same worker. After this happened, he wrote a letter to the NRC and then also accepted the invitation to sit on Lloyd's Task Force that had been established in 1973 within the framework of the Conference of Radiation Control Program Directors.
Spell then related that Lloyd has indeed 6
drafted a letter for submittal to the Executive Committee of the Conference some time this month, expressing support for the Policy Committee's efforts on personnel dosimetry and for efforts to improve neutron dosimetry. There should be no problem to get support from all the states, both for increase in research efforts and s tandardization on the state-of-the-art level.
Va11ario added that if the states felt that there was a need for both research and standardization, they should state it.
The only research on neutron dosimetry going on in the United States is that on track etching at Livermore.
Unfortunately, there are no new ideas.
In order to stimulate new ideas, the DOE and the Central Electricity Generating Board are co-sponsoring a by-invitation-only workshop in London.
Europe was chosen because it will be easier to get international participation (Russia, Poland, Italy, where Tomasino seems to be focussing on microdosimetry and delta-ray spectrometry).
He is hopeful
4,
that the workshop will stimulate new development, just as it stimulated the use of TLD for personnel dosimetry nine years ago.
Finally, Palmiter asked Spell why the personnel-dosimetry processors seem to get along better with states' authorities than with the NRC, as had been commented on in the 1976 public meeting.
Spell answered that this probably is the case because, in many states, the regulatory functions are less penalty-oriented than at the NRC.
7.
Action Regarding Overview Committee.
Leiss distributed copies of a draft letter from him to John Campbell, LLL, in which he informs him that it would not be acceptable to have an Overview Committee advisory to NBS.
If there were such a Committee, NBS would be drawn in o the regulatory chain.
The members of the Policy Committee read the letter. There was a brief discussion, initiated by Leiss, on whether any members of the Policy Committee would be bothered by the idea of an independent Overview Committee.
Alexander mentioned that he already has informed Campbell in writing that NRC would listen to such an outside group.
Va11ario added that the HPS has a standing committee on state and federal regulations that could handle this and--according to Alexander--Campbell already has talked to the HPS about working through them.
The members of the Policy Committee then approved the letter to Campbell, with one change suggested by Alexander.
(Write "... provide comments to the NRC" instead of "... advise the NRC"). A copy of the final letter is attached to these Minutes.
t
.g.
8.
Extension of Committee's Scope to Certification Program for Other Radiation-Protection Instrumentation.
l Vallario gave a brief background statement:
In December 1977, Eisenhower and Heaton of NBS sent an inquiry to Richard Burk, Secretary of the HPS, to determine whether the HPS would be interested in a cooperative effort to assemble and publish a directory of the companies engaged in performing calibration services for portable protection instrumentation, since they felt that such a directory would provide a useful service to the health physics community and would facilitate the use of calibrated instruments.
The question was brought to the attention of the Board of Directors of the HPS.
They rejected the proposal because listing such centers would mean to sanction them. At the last annual HPS Meeting in Minneapolis, Eisenhower, Heaton, Selby (BNW) and others from BNW met with Va11ario to explore further under whose auspices a list of this nature could be prepared and published.
This meeting was followed up by a meeting in Vallario's office, in the presence of representatives of BRH and NRC. At this meeting, the scope of the endeavor was redefined, and it was decided that what was really needed were guidelines for test procedures, much like those being set up for personnel monitoring.
Vallario suggested the use of this Policy Committee as an interagency forum for this undertaking.
Judging from the poor performance of radiation instrumentation, there should be no problerr to justify looking into the adequacy of measurements, keeping in mind the need for low-dose measurements, epidemiological studies, etc., which have the prerequisite of standardized test methods.
Va11ario therefore proposes to extend the work of this Committee to look into standardization and testing 'of portable radiation instruments.
Phase 1 would entail:
v 1.
establishing existing capability; 2.
approaching HPS to develop test criteria; and 3.
setting up a laboratory to check out the criteria.
A discussion followed on the desperate current need for work in this field, including education regarding the appropriateness of certain instrumentation for a given task and the need for proper calibration.
Miller pointed out that, at D00, there are more problems with portable health physics instruments than with personnel dosimeters.
Vallario added that good dosimetry with portable instrumentation actually is more important than good personnel dosimetry, since it is used to establish the crucial " stay time". Miller, Alexander, Thompson, and Spell were positive.
Spell suggested particular emphasis on training, Alexander thought the Committee work could be instrumental in the rule change, and Thompson said it would fit in well with BRH's interests in exposure reduction.
Garcia wondered if this Committee was the right place for this project, which as Vallario suggested could be taken care of formally by having the Committee adopt a more appropriate name.
Leiss then tabled the matter and suggested that the topic be placed on the agenda for the next meeting.
9.
There was no further new business to be discussed.
It was decided to schedule the next meeting tentatively for 2 p.m., November 7, again in Leiss's office, since Alexander and Palmiter felt that they would have a draft to pass out by mid-October.
Adjournment followed at s 4:45 p.m.
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