ML20147D309
| ML20147D309 | |
| Person / Time | |
|---|---|
| Issue date: | 11/07/1978 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19220A229 | List: |
| References | |
| RTR-REGGD-08.013, RTR-REGGD-8.013, TASK-OH-902-4, TASK-OS NUDOCS 7812190212 | |
| Download: ML20147D309 (115) | |
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N'U CLE A R Rg o y L A7e gy CO MMISSIO N - '
IN THE M ATTH O F:
NRC STAFF AND UNION REPRESENTATIVES MEETING ON PREPARATION OF REGULATORY GUIDE ON RISK FROM OCCUPATIONAL RADIATION EXPOSURE Plc18 - 3e'.hesda, Maryland
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UNITED STATES 0F AMERICA' CRAIG:mp NR 2 NUCLEAR REGULATORY COMMISSION 3
4 NRC STAFF AND UNION REPRESENTATIVES .
5 MEETING ON 6
. PREPARATION OF REGULATORY GUIDE ON RISK 7
FROM OCCUPATIONAL RADIATION EXPOSURE 8
9 Conference Roon P-ll8 '
jo Phillips Building 7920 Norfolk Avenue 11 , Bethesda, Maryland
-Tuesday, 28 November 1978 12 The meeting was convened, pursuant to notice, at 9:20 a.m.
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2 IR 1516 #1 a::'l 1 PEEEEEElEEE 2 MR. ALEXANDER: I would like to welcome all of our 3 visitors from the various unions here this morning. We 4
appreciate your coming, some of y6u from fairly long distances, 5
to deliberate with us on this particular regulatory guide.
6 I believe it is the first time we have gotten 7 together for a purpose like this, and it will be interesting 8 to see.how we come out.
9 I would hope we will be able to do more and more 10 of this as time goes by, not only on our regulatory guides, 11 but on our regulation changes we work on.
12 I am Bob Alexander from the Occupational Health 13 Standards Branch in the Office of Standards Development, and 14 probably the person that you have had most contact with in 15 recent years.
16 When we were with the old Atomic Energy Commission, 17 Je had an advisory committee.which included union representa-18 tion, called AELMAC, Atomic Energy Labor and Management 19 Advisory Committee.
20 Paul Shoop, who is here today, I remember, was a 21 member of a labor representativo to that committee. We had 22 an opportunity to meet with them whenever we needed to, to 23 discuss proposed rule changes and things like that to get the 24 labor input. That committee was abolished when the Nuclear rFunral Romrte,s. inc. l 25 Regulatory Commission was split away from the Atomic Energy I
, ah 2. 3 s
1 Commiss_ ion, and.sinen..that tima our relationships with tha 2 unions as far as occupational health protection standards is 3 concerned, has been rather rpanmodic.
4 One of the things we are trying to do with this 5 meeting today is establish precedent for closer interaction 6 with respect to some of these standards that affect your 7 members.
8 I want to take a little extra time this morning, 9 if you will permit me, to give you a fairly comprehensive 10 introduction to the Occupational Health Standards Branch, 11 since it is the one that deals most directly with things that 12 affect your members, i
13 I want to describe the branch a little bit. There 14 are 10 of us. We work full time on occupational health 15 protection. The staff members are senior people, GS-13, 14 16 and 15. They are all highly educated in the science of 17 health physics. Three of them have Ph.Ds, one has a Master's 18 degree, two of them are graduates of the AEC Fellowship 19 Program which is the equivalent of a Master's degree. Some 20 of us have as much as 25 years of experience in occupational 21 health protection.
22 I don't believe there is anyone in the branch who _,
23 has less than seven years experience. So we feel like we have l 24 a qualified group of individuals to deal with occupational foo:ral R porters, Inc.
25 health protection in the radiation field.
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sr3 4 l I 1 As to our output, I have put together a list of 2 some of the documentation.
3 Alan, would you _ pass out to our 4 union visitors a list. This is a list of the principal docu-5 ments issued by the Occupational Health Standards Branch over 6 the past few years. All of these are available.
7 If you see anything on there that you want a copy 8 of or that you want to read, just let me know.
9 Let me stop at this point and give you my telephone 10 number. It is area code 301-443-5975. If you want to write 11 to me, it is the Office of Standards Development, Nuclear 12 Regulatory Commission, Washington, D.C. 20555.
I 13 This list mentions first the two principal regulations 14 that govern the protection of workers. Part 20 and Part 19.
15 Then follows a list of regulatory guides that we have issued.
16 I don't see any point in reading that.
(Set h'"*. l f *f H. h 17 I am having them entered into a transcript. There A
18 will be a transcript of this meeting which will be available 19 to you if you want it.
20 There are several reasons for the transcript.
21 There are a fairly large number of NRC people, particularly 22 in upper management levels , who are not able to attend this 23 morning, and I want them to have an opportunity to review this i
24 transcript, and also to make it available to anyone in the neero Reporteri. ine. ;
25 public who has an interest in seeing what is said here today l t ,
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by cither NRC personnel or union perscnnel.
2 Over on page 3, you can take a look at the regulatory l
3 guides that are under development. By under development, that 4
means I have somebody working on 'the guide right now. Listed 5 at the bottom of page 3 are the reports that we issued.
6 No, there are three levels of documentation:
7 Regulations, regulatory guides, and topical reports.
8 The regulations are the law of the land.
9 The regulatory guides give one way to comply with 10 a given regulation, although these guides are not compulsory II and other ways that are just as good or better are acceptable 12 to the NRC Staff.
13 Then the topical reports we use simply .to disseminate d
Id information to our licensees that we think would be helpful I5 to them in reducing worker exposures.
16 In addition to this list, I want to call your atten ,
i 17 tion to a few other things that I don't have in a handout. i i
18 In addition to the regulatory guides, we expend a fairly large !
19 effort in keeping the regulations up to date, particularly 20 Part 20.
21 Some of the rule changes that we are working on now calibration 22 include a rule change on instrument cricu12:icn. By instrument,,
23 of course , I am referring to health physics instruments, 24 instruments that are used to make measurements to orotect
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3 Foceral R eoorters, irsc. l 25 workers. I i
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ar5 6 I Rule change on the transient worker problem which -
2 would cause our licensees to control the radiation dose, the 3
total radiation dose to the worker. As things stand now, 4 he's only required to control the' dose that he gives the 5 worker. According to this new rule, he would have to control I 6 the total dose during each calendar quarter. So he would.have 7 to find out what the dose was, for example, at a power plant )
8 or other power plants during the quarter, and then he.could
-l 9 only give the worker the difference between that amount and l
fos t 10 the NRC skvA limit. ,
l II Another rule change we are working on is on 12 personnel monitoring rpeorts, where we are -- well, actually, 13 this one just became effective. It extends the personnel 14 monitoring reports requirement from just the four categories 15 of licensees that have been reporting to all licensees. It 16 will give us a much better data base for our regulatory 17 program, among other types of licensees.
18 We have a rule change that we are working on now l9 which would remove the use of the five times N minus 18 formula 20 which I think many of you are familiar with.
21 This is the formula which essentially allows 22 workers to receive as much as 12 rems annually. By removing 23 this formula, the limit would be reduced to 5 rems, upper 24 limit would be reduced to 5 rems annually. 12 rems annually :
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l 25 reduced to 5 rems annually. j.
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Another rulo chango wa have before the Commission 2
now would put some teeth into the occupational ALARA concept.
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We have an c'ren Part 20 regulation that requires that 4
radiation doses to workers be kept as low as reasonably 5
achievable. This rule change would make that concept 6
enforceable and inspectable.
7 We have made our presentation to the Commission, i and we are wait'ing now for their agreement or disagreement 9
with the Staff on that particular rule change.
10 VOICE: Has that one been proposed in the Register 11 yet?
12 MR. ALEXANDER: No, it is before the Commission now 13 asking their permission essen'tially to propose it in the )
14 Federal Register.
15 Another rule change that we are working on has.
16 to do with occupational radiation dose limits. We will get 17 into more later in the day, A number of rather prominent 18 scientists, some of them, have made the point that they feel 19 that the occupational dose limits, even at 5 rems per year, 20 are too high and should be lowered.
21 We have a petition to that effect from the Natural 22 Resources Defense Council that we are working on. We have 23 had recommended to the C'emmission that a hearing be held, a j 24
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i 25 expect, or we anticipate a f avorable response from the i i
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Commission on that recommendation.
2 The last rule change that I want to mention, 944 3
there or others we are working on, has to do with radiography 4
safety. We have two rule changes in progress to increase 5
the degree of safety afforded radiographers. One has to do 6
with procedural aspects and the other with design.
In addition to these tasks that my people work on, 8
I feel well supported by the NRC with respect to getting 9
support from outside the agency. We have three ways that that 10 is done:
11 One is that we are permitted to engage consultants.
12 We have two consultants for my branch, and are thinking about 13 adding at least one more, to work on special projects on a 14 part-time basis.
15 One of them is a man you may have heard of, 16 Claire Palmiter, who is the president of the International 17 Radiation Protection Association.
18 A second way is thre. ugh what we call technical 19 assistance in which money is set aside for the occupational 20 Health Standards Branch to contract with laboratories and other 21 firms to work with us in support of the Occupational and Health 22 Safety Program.
23 There are a number of those I would like to mention !
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to you this morning so you will know what is going on. :
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25 i We have a contract with the University of Michigan i l
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I to perform c pilot study on personnel dosimetry accuracy 2 testing. We are convinced that a number of the processors 3 whoido _f(km_ badge s ,_ TLDs and so forth, are not adequately 4 accurate in their work. We look forward to a rule which would 5 state that the NRC will only accept personnel monitoring data 6 which is acquired by a processor who has successfully passed 7 some accuracy testing.
- 2 8 We are conducting a pilot test, the University of 9 Michigan is conducting a pilot test under contract to us right 10 now. You might be interested in keeping up with that.
11 Everything that we get in from the University of Michigan goes 12 into the Public Document Room. You are'welcome to examine the 13 progress reports and other things that are coming along.
14 The results, we are about halfway through the 15 program now and the results are not encouraging. So I think 16 this is an important effort that the NRC has embarked on.
LewoY \
17 We have a contract with the University of Lcy:1; 18 to develop a program for radiographer training and testing.
19 That one is, I'd say, about 3/4 complete. We support at 20 Los Alamos Scientific Laboratory a respiratory protection 21 laboratory in which a group of -- what, Jerry , ' about a half 22 a dozen people who are experts in respiratory protection, 23 spend full time on that, and are very well equipped to do both i
24 developing and testing of respirators, conduct a very helpful
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25 effort for us. i l
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1 I will talk a little bit more about their eark 2 later.
3 At Battelle Northwest Laboratory, tests are 4 being conducted of these pocket alarm dosimeters, the ones i
5 that have audible alarms. We are becoming more and more 6 interested in those dosimeters, and we feel that we have
'7 to have more information about their reliability before we '
8 would consider any sort of regulation that would require 9 "their use.
10 We have another contract with Battelle Northwest 11 Laboratory to test the conversion factors that are used in 12 conve$ ting the dose that is received at the surface of tissue 13 and at the deeper organs. Factors are available now that we 14 are using,but they are theoretical and haven't been tested 15 by actual measurement.
16 So we are having those measured to try to make 17 sure that we are using acceptable factors. We have a contract 18 with the National Bureau of Standards to help us with regard 19 to regulations governing the calibration of neutron 20 dosimeters, which is a special type of radiation that is more 21 difficult to deal with than gamma and beta radiation.
22 We have a contract with Oak Ridge National 23 Laboratory to help us in the special problem of internal ,
1 24 dose calculations, which are difficult, and which we will be t l'
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25 getting into fairly thoroughly in the ecming months because of ne l '
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recommandations from the International Commission on 2 Radiological Protection with regard to radioactive-material in the air.
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That's our technical assistance program which runs 5 on the order of 300- to 350,000 a year in addition to the'10 l
6 people that we.have on staff and the consultants. '
7 Then in addition to that, the Office of Research ,
l 8 'in the NRC conducts-work for us. I didn't add it up, but 9 it is on the order of a half million per year in support of 10 the Occupational Health Protection Program.
11 I want to mention r'^'?t just a- few of the things 12 that they are funding for our branch. One is at the-Los 13 Alamos Laboratory that I mentioned a moment ago. They are 14 measuring the protection factors that ara actually afforded 15 by respirators to workers. Workers of many different size
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16 faces don respirators that have been modified such that the 17 concentration of particles inside and outside the respirator 18 can be measured. They go into a special chamber and do various 19 exercises to simulate working conditions, and the protection 20 factors are actually measured. Those we go by in our Reg 21 Guide 825.
22 Another project at Los Alamos is the development j 23 of a radiciodine respirator. The task there is to develop 24 performance criteria for the respirator and methods by which -
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25 the performance can be tested.
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After that's been dono, wo expect the industry to 2
pick up the' ball and manufacture a respirator that can be used 3ll for protection against radiciodine.
4 Another study that is being funded for us at the 5
University of Rochester has to do with the metabolism of 6
UF which converts to co 22 F immediately when released to the 6
7 atmosphere to determine the degree of hazard associated with 8 those exposures in the fuel cycle facilities.
9 Battelle Northwest and the Loveless Foundation are 10 doing studies for us to determine the solubility of yellow 11 cake.
M Workers in uranium mills and in some fuel t,ab- plants 12 are exposed to yellow cake, which is a form of uranium.
13 We are doing two types of studies. One is called Id in vitro, which has to do with measurement of the solubility 15 of the material in the test tube.
16 The other one is a human study being done for us ,
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17 by Battelle. This will be a rather long term one. What we l l' l 18 are doing is sitting around something like bureaucratic l l
I' vultures, I suppose, waiting for an accident to happen, and l l
20 accidents 'o d happen. We can't completely prevent them.
21 When one does, we have made arrangements with Battelle to 22 fly the unfortunate fellow who is involved in the accident 23 back there to their plant and keep him away from any other 24 uranium exposure for several weeks while we measure the t
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25 excretion rate in urine and feces and do the chest counting on ;
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.- a,r12 .13 I him.to get' actual studies of the.-behavior of yellow cake in 2 the_ human body..
3 Also, at the Loveless Foundation, they are continuing I i
4 to do animal studies for us t'o investigate the hot particle- .
5 problem. I don't know if that term hot particle is familiar 6 to all of you or not. It has to do with tdue very tiny particien 7 of radioactive mate, rial that sometimes get into the lower 8 lungs.of workers. Whereas the whole lung may not be irradiated ,
9 very much as would be the case with external exposure, the 10 area or volume of tissue right around the particle is II irradiated to extremely high levels. I 12 People have been interested for a long time in 13 finding out whether those particles are more or less dangerous 14 than uniform radiation. These studies are designed to put 15 that question *to rest. )
16 Finally, I want to mention the research effort !
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17 that is being conducted by several laboratories which has to 18 do with the special uranium or dust standard that the l
l l 19 Commission has been using for several years. It's been called 20 into question, and we are doing a very comprehensive set of-21 testing to determine the adequacy of that standard.
22 The additional support for our branch comes from 23 the industry. Scientists in the industry in a voluntary standard i
24 program, which is usually referred to as the ANSI program, !
oreno newwn, w. i 25 American National Standards Institute. What we normally do whed 4
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, arl) 14 1 we feel that a particular standard should be developed by the 2 industry, we write a request to the Health Physics Society 3 Standards Committee which appoints a working group to develop l 4 a standard which is eventually issued as.an ANSI standard.
5 These then we use as regulatory guides.
6 So this augments the work of my branch tremendously.
7 Let me just mention to you the titles of a few of 8 the standards that are being worked on now. There is one on 9 the techniques for air sampling in which we feel that a lot of 10 ; improvement is needed.
11 There is one on personnel dosimetry accuracy 12 performance criteria.
13 One on health physics survey instrument performance 14 criteria. i
, 15 One on bioassay laboratory performance criteria.
16 And another on in vitro counting performance 17 criteria.
18 There is still another on alarming dosimeter !
19 performance criteria and three on bioassay, one for 20 plutonium, one for tritium, and one for fission and corrosion 21 products.
22 Well, I took quite a bit of your time to describe 23 the effort of the Occupational Health Standards Branch and 24 to try to leave you with an accurate description of what t
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25 Uncle Sam is paying for in workerprotection through this agency.1; 1
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arl>4 15 1 I personally am very proud of this program and 2 very content with the amount of support that the NRC is 3 giving to work' protection, and I hope you feel the same way.
4 To get around now more' direct 1y to the subject of 5 this meeting, the Utility Workers Union of American contacted 6 me a few months ago and said that they had an important 7 matter that they wanted to discuss. We met a few days later.
8 I felt they made a very reasonable request of the NRC. It 9 was based on the, as I understand it, responsibility of the 10 federal government for a regulated industry to tell workers 11 in the industry what the risks they are being subjected to are, 12 and something that they at least feel the NRC has not done 13 adequately, since the question about the dose limits has arisen 14 in the past few years.
15 I will say the last two years.
16 They essentially requested that the NRC inform all ,
17 of their menbers as to what the risks are, and that this be l' I
18 done in the training classes that the NRC requires for workers 19 at nuclear power plants; that the training be done by NRC cn 20 employees; and that if for any reason the training ese/dno&
ne be 21 done, this is strictly the training on risk, now, I don't 22 think they intended to include all of the training, but the 23 training on risks from low level radiation; and that if for 24 any reason the NRC couldn't do this training, that the NRC e seco nemrms, ine.
25 require that the training be done by contract personnel.
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l arl'5 16 to do 1 It did not work for thn utility O._..g the training.
2 I took the position at that meeting that I was sympathetic
- 3. with their complaint that the NRC hadn't officially spoken 1
4 out as to its position on these risks. .But I said I didn't 5 think it would be possible for us to do this training ourselves ,
6 I'wasn't sure that it would be possible for us to 7 require a licensee to use a contractor rather than.his own 8 qualified health physicists to do the training.
9 So, in our negotiations we arrived at a compromise 10 which was acceptable to that particular union, and a 11 compromise which I hope that the other three -- I believe there 12 are either three or four other unions present today -- will 13 speak out on during this meeting. And that is the issuance 14 of a regulatory guide based on Section 19.12 of Part 19 of 15 the Commission's regulation which would enable a worker who 16 is accepting a job at a licensed nuclear power plant to read 17 the guide and come away with a reasonably good idea of the 18 risks from low level radiation as we understand them today, 19 and to feel like it was Uncle Sam talking to him.
20 I don' t really want to say much more about that l
l 21 right now because I called Jim Joy yesterday, of the Utility 22 Workers Union of America, and asked him if he would this morning 23 make essentially the same talk to you that he made to me with ;
24 respect to that union's position regarding this guide.
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25 So, Jim, if you will come up here now and talk to l l l I r
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h816 17 I thogo people and tell them about what you told me, then after l 2 that we Will go to work on finding out what you think about this l l
3 guide. l 4 MR. JOY: Thank you, B6b.
5 We~ represent the people up in Local 1-2, Utility l
6 Workers of New York City, representing the plants of Indian 7 Point 1, 2, and 3.
l 8 Indian Point 1 is down at the present time. Our I l
9 national union represents 13 nuclear plants throughout the 10 country.
II The problem we ran into was at the last major '
12 outage. Prior to this point I don't think anybody was assessed 13 of the possible problems of radiation to the degree that there 14 was great concern.
15 Since that time the concern has become very i
16 evidense We met with the NRC to, discuss problems we felt with i
17 our own membership. Simply this, that reading in the news-18 paper, the media, and what have you, the concern of 19 radiation workers now is something that has to be answered.
20 We weren't too happy with the procedure that the 21 Edison Company, who owns those two plants, prepared at the 22 time or indcetrination period or involvement in what type of 23 risks are involved with radiation workers. There was a crash 24 program. A person who had never seen a nuclear installation ,
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- 25. was brought into a room and for eight hours crammed into his i
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head as to what to expect, never even seen the property 2
perhaps that they were going to work into. And all the 3
information that was prepared was prepared by the Edison d
Company itself or the companies. I dont know how it is with 5 the other companies.
6 We weren't satisfied with the way it was presented 7 because it was presented in a way that it would seem that there 8
was no risk whatsoever or the worker himself or herself could 9
.not relate the risk in fact involved. Simply this, try to 10 rationalize that a worker, not understanding the scientific Il jargon of radiation, all of a sudden has to compare with 12 the risk factor is going in to work at a nuclear
- installation.
13 He just can't possibly do that. Talking about an average 14 worker. Talking about somebody who never even understood 15 they would probably. be going into a nuclear installation.
16 Many, many times this is the first time they are i
17 going into a nuclear installation for any type of repair. I e2 18 19 20 21 22 23 24 , i pFcoorti Reporters, Inc.
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16.03.1 19 LT 1 We are not talking about a nuclear worker assigned 2 to a plant permanently on a permanent basis. Those people, 3 I think, understand the risk perhaps better becausa a lot 4 of them came out of the nuclear service 'in the Navy and 5 nuclear submarines and what have you.
6 We are talking about the repairmen. The worker 7 who has to go in.whe.n outages come about. The worker who has 8 to go into the high contamination areas. We are talk Lng about 9 the people who are siso there on a permanent basis but
- 10 basically the people who are regular or possibly translents 11 in the company they work for.
12 '
We.11, .what we tried to bring up to the Nuclear 13 Regulatory Commission is the v'ery real fear of these workers 14 and there is a f ear there today.
15 It's the fear of the unknown because nobody really 16 is teillng them the true story. We wanted some type of gulde, 17 1.f the Nuclear Regulatory Commission couldn't send their own 18 personnel up to do the training or were .not obligated to tell 19 the licensee to go out and get outside contractors to do it.
20 we just don't trust, or the people don't trust the preparation 21 of the traini.ng program by the individual company itself.
22 But we wanted something to be drawn up where they 23 could make an intelligent comparison as. to what the risk, if 24 any. is if they go into that . nuclear installation to do any 25 type of work and take any type of low-level exposures.
ACE-FEDERAL REPORTERS, INC. (202)347-3700
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LT I We try to put it in a vein that the Nuclear 2 Regulatory Commission could understand, that, for instance,
- 3. if three cigarettes a day'were smoked and so much radiation l
4 was exposed to the radiation, that this 'is what would come out l
5 in the end.
6 Soma type of comparison where the average worker 7 coul.d understand very simply as to what the risk f actor is 8 working in a nuclear installation. I think we brought it home l 9 to Bob when we indicate the different' salaries that people 10 were making while they worked in a nuclear plant. l
.11 And even with those type of salaries,. refused to- go.
12 - We have a Nuclear Safety Committee in our own local which the 13' NRCwasgracious/enoughtosendBobAlexanderuptoexplain i 14 the risk factor Involved with working at different exposure 15 levels.
16 We also contracted with Brookhaven Institute out in 17 Long Island for seven separate lectures for our Nuclear 18 Safety Committee so they can understand. But this again is !
19 a saf ety committee understanding something.
20 It's not filtering down to the worker in volume. Our 21 problem is we try to indi.cate to the company that this 22 requires a great deal of training, a great deal of explanation 23 to the worker.before that worker is to be expected to go into 24 a nuclear Installation. To make their own decision in the 25 end.
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@l6.03.3 21 LT 1 But they should have the .right to the Information 2 to make that decision Intelligently. And that's what this 3 was all about. So, Bob, I think ,that about completes it and 4 IL appreciate the help that you have giv;.n so f ar.
5 Thank you.
6 MR. ALEXANDER: .Thank you, Jim.
7 I would like to introduce you now to a . fellow who 8 will be moderating this meeting today, Alan Roecklein.
. 9 Alan has' prepared and sent to you, some material, 10 a list of questions that he has made up that he. thinks would
.11 do the job if good answers were given as an appendlx to this 12 regulatory guide that we are thinking about.
13 Is there anybody from the unions who didn't get or 14 doesn't have a copy of those questions?
15 MR. ROECKLEIN ls there anybody that would like 16 some?
17 MR. ALEXANDER
- What we are going to try to get ,
18 away wlth today is just deal.ing with questions. If you want 19 to deal with the answers, I guess we will try that, t oo ,
20 althcugh we are not as prepared as far as the answers are 21 concerned as we are the questions.
22 We would like, when this meeting is over today, and 23 we go back to our of. flees, we would like to know, number one, 24 whethe: o. .t ycu feel that a regulatory guide like this 25 should L in *d, a r.isk, gulde on risks should be issued.
ACE-FEDERAL REPORTERSr INC, (202)347-3700
B i d . 03. 4 22 LT l- Number two, what sort of form or format do you think 2 it ought to take, whether a question and answer format like 3 we are suggesting, or some other, format. And if you agree
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4 with the question and answer format, do we have all of the 5 questions here that ought to be answered?
6 or are there others that you know from your contact 7 with your members that they have on their minds that still 8 wouldn't be answered if we issued the guide.
9 We have had a spokesman from the Utility Workers 10 Union of America. Is there anyone else representing any of the
.11 other unions who would like to make any kind of statement 12 at this time? '
,13 Steve Wodka from the oil, Chemical and Atomic Workers 14 Union.
15 MR. WODKA: I am an international representative 16 with the all, Chemical and Atomic Workers, I am here in 17 Washington, I am assigned f ull-time to the health and saf ety 18 of our people regarding all of the regulatory agencies we have 19 to deal with, not only NRC but OSHA, Department of Energy and 20 so on.
21 One thing that I don't think has been mentioned.here 22 is that there also was another meeting, I guess it was 23 subsequent to the meeting that was held by Mr. Alexander with 24 the Utility Workers. That .was held between representatives of 25 our union and Mr. Alexander. We have a very strong difference-
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e A 16.03.5 23 LT 1 of opinion as to the purpose of this effort that. is being .made 2 today in terms of this booklet. this Regulatory Guide.
3 In our view, this agency, the responsibility of this 4 agency is to eliminate the risks to nuc1' ear workers.
5 thrt to make the risk a cceptable to nuclear workers.
6 And in our view, that is preclsely what the proposal would 7 do. And there is, we very vehemently and strongly object to 8 this agency taklng on this kind of a task when it should be 9 expending its ef f orts in eliminating these kinds of risks.
10 Now, it give you some examples. We take a look at
.11 the Regulatory Guide that's been proposed here as an example 12 which is Regulatory Gulde 8.13, on prenatal radiation exposure.
13 This document is just abhorred to our union in 14 that it equivocates. the rlsk to the unborn child, makes it 15 equal to the mother climbing a f ew steps or smoking a f ew 16 clgarettes. You cannot compare that to the risk of leukemia 17 that a mother would get, that a child would have lf her mother 18 or his mother worked in a nuclear f acility if the exposure 19 was above a half a rem during the period of pregnancy.
20 But worse than that, instead of this agency, and 21 I was present at that meeting when it was the old Atomic 22 Energy Commission, instead of.this agency requiring that 23 fertile female women who are pregnant or expected to be 24 pregnant be placed in an area.where the exposure was less than l 25 half a ren, and that their rate of pay be retained insteed, 1
l 1
l ACE-FEDERAL REPORTERS, INC. (202)347-3700
16.03.6 24 l LT 1 the entire burden was shif ted upon the mother, to either leave 2 the plant entirely and suffer that economde loss, or to bid 3 out or transfer out to probably a, lower-paying job and take the 4 full economic consequence of.that, instead of this agency 5 requiring the licensee to place that woman in that 6 lower-exposed job at the same r. ate of pay.
7 That is what we mean by positive,'to protect ,
8 workers. And I think that the people in the union movement 9 know that risks in the f uture, risks of cancer, risk to the 10 unborn child, are not as real to a worker as the paycheck that
.11 they need that comes in every day.,
12 Workars are always placed into.this box over needing 13 that money today versus some kin'd of unknown risk In the 14 future.
15 What we need is positive action now so that we can 16 retain these economic benefits that we need to support our 17 f amilies, and, at the same time , that we know that our healtn 13 will be protected and the hecith of our offspring will be 19 protec.ted in the future. ,
20 Not a gulde that will allow the licensees more or 21 less to get off the hook by giving our people a piece of paper 22 and saying, "Look, read this and that's all you have to worry 23 about, and go on into the plant."
24 So I wanted to state our objections. We have no i
25 objection, though, to the fullest and freest exchange of )
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$ 16. 03. 7 25 LT 1 information from this agency to the workers and their l
- 2. representatives on what is known about the hesath eff ects of 3' radiation.
4 A lot of informatlon that this agency has that we ;
5 could. u se , I found that your listing of the research that this 6 agency is conducting-very interesting and will be very helpful 7 to us in the future.
8 We have no problem with the data coming to us, and 9 your results of your studies coming to us. But it's our 10 view that a Regulatory Guide .in the fctmat that has been
.11 proposed is going to have the opposite effect than what is 12 being sought here.
13 MR. ALEXANDER: Thank you Steve, for that opposing 14 viewpoint. ,
15 Another union I contacted on this problem was the 16 Brotherhood' of Electrleal Workers which is represented by 17 Paul Shoop, who is here today.
18 Paul, I think we ought to hear from you as far as 19 your views are concerned.
20 MR. SHOOP I t's best to keep your mouth shut but 21 since I am going to open it, I will put my foot in it also.
I 22 We support the Utility Workers Union of American in 23 the need for a risk. identification to the workers. The IBW, 24 again, the IBW, we have to particularly deal with the power 25 r e a.ct or s . This is where most of our experienes and most of ACE-FEDERAL REPORTERS, INC. (202)347-3700
116.03.8 26 LT I our man.bers in the nuclear industry are located. It goes 2 back to the beginning in 1957 when the first power reactor 3 came onstream. ,
4 The IBW since that time has tried to get as much 5 Information to its members that work in a nuclear power 6 reactor as possible. Very early on, wo did some rather-7 unsophisticated risk assessment. We can take the mortality 8 tables and take the causes of death, particularly those causes 9 that people less like, such as cancer.
In We know how many people a year die from cancer and
.11 dlfferent ages and such as this. We can express this in 12 rather unsophisticated terms to our members and compare ~ it 13 to their experience. At.the licensed reactors, we have 14 lost no members due to any fatality due to radiation. We have 15 had very few incidents even involving radioactive material.
16 We have had a f ew over-exposures to our members. Our 17 members by and large do not express a great deal of fear to 18 us because on a continuing basis, we get the inf orma. tion to 19 them. We have a monthly journal such as all the unions have 20 and routinely throughout the year, articles of interest 21 to our members are expressed.
22 In addition, the IBW has regional utility i
23 conferences, and all our members at the power reactors are in 24 what we call the utility branch. We meet regionally with all l l
25 our districts throughout the nation. And we discuss any l l
l ACE-FEDERAL REPORTERS, INC. (202)347-3700 !
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16.03.9' 27 LT 1 problems that we have. So. we have an ongoing dialog with I
'2 our membership.
- 3. The low-level radiation problem has made some 4 more questions. . -Not nece ssarily of f ear, but can my
[
5 exposure'cause' cancer? From the' levels of exposure that the 6 members report, the cumulative exposures, and what data, and-7 we by no means are experts, but what we read, . we have to say.
8 no, ' we . probably have not ' had a cumulative exposure that 9 triggered any cancer that caused a death to our member.
10 But this is one area that has to be acdressed. The J1 electrical . field is 'somewhat of a hazardous field. On an 12 average, we lose 50 members a year to electrocutions. We 13 lose members to 'the .other hazards such as falls and, you name 14 it, getting mangled in machinery.
15 So we do understand' there are risks associated with 16 the particular industry that all our members work with. Our -
17 members who work at the nuclear power plants know that there '
13 have been no deaths due to radiatlon. Yes, we have had an ,
19 electrician killed at a nuclear power station but he was '
20 electrocuted.
21 Radiation played no part. We had another member 22 killed at another nuclear reactor. He fell through an open 23 grating. Radiation had nothing to do with it.
24- So our members can pretty'well sort the risks out if 25' we give them the facts. This is all they' want. They want ACE-FEDERAL REPORTERS, INC. (202)347-3700
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l 6.03.10 28 LT' I the facts. And I think the Reg Guide that is proposed is one l 2 means of getting as much information to our members about the 3 field they are going to work in. . I 4 And, of course, hopefully, as new information is 1
5 available, the Reg Guide will be updated the same as all the 6 other Reg Guides are to incorporate any advanc.es.
7 We at the IBW think this is a worthwhile project.
8 MR. WODKA8 I think someone has to comment on what 9 you have said. There is one reason you.may not have seen 10 the cancer we are ' f earf ul about at a nuclear power plant.
.11 That is that most power plants are relatively new, 12 even some of the older ones are relatively new if you look at 13 the issue of how cancer, of. when cancer is manifested. Most 14 occupational cancer, which is what we are talking about here, 15 has a latency period of 15 to 20 to 25 years, 16 And that's why you are only seeing cancers among.
17 people exposed to radioactive products who have been in 18 the industry for a long time like uranium miners who we 19 represent in New Mexico, where the rate of lung cancer is 20 fantastically high.
21 or as Mancuso found in Hanford, which is one of 22 the older f acilities operated by the government, that goes 23 back and predates a lot of the power-generating stations that i 24 we ha ve. I think we have got to be honest with the f acts. l l
25 The generating stations for the nost part have not !
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,16.03.11 29 LT l- been around long enough for the cancer to be manif ested.
2 You might be right in what you say, you haven't 1
3 seen.them. -But enough time has not-yet gone by. . l 4 MR. SH00p Well, there has been at least 20 years, 5 Steve, and I agr.ee statistically we are talking- about a large- !
6 number, but we have had 20 years, and there are more than 7 one, there are several that .are this old. On lung cancers, ,
8 this is a different issue, this comes under MESA and not 9 NRC.
10 MR. JOY.: I would like to ' reply to this gentleman,
.! ! too. You.are coming in with fact. You are saying these are 12 probabilities or possibilities? You are not'sure. Now, 13 just a second, I would like to say something on that.
14 Because this is the thing-that is happeni.ng to our 15 members right now. We want to be sure, we expect the people 16 who license these plants to tell us what the true f acts are 17 as they find them with the best expertise they can have.
18 Not one scientist. not two scientists, the best.
19 The best in the world. We expect that Information.
20 If they are going to license these plants, they owe i
21 us that. We expect them to give it to us. We expect our 22 government to tell us the truth and we want our members to 23 know exactly what the truth is.
24 Not what.somebody else is saying.
25 MR. WODKA: Look, don't get me wrong. We don't have ACE-FEDERAL REPORTERS, INC. (202)347-3700
$16.03.12 30 LT 1 any problem with the government telling the truth. The j 2 question is, is this agency in the position .of telling truth 3 to our people? ,
4 MR. JOY: That's what we are trying to force.
5 MR. WODKA: Well, our experience shows it has not 6 told the truth to the workers in the past. And the things 7 that it has on the books now, like this Regulatory Guide for 8 Women, does not .tell the truth to the ris ks to the fetus.
9 That is why we are here. Maybe our experience has 10 been different than yours. But this is what we have found.
.11 MR. ALEXANDER: Things are warming up a little in 12 this meeting. We have a union. represented by these two 1.3 gentlemen right here. I wonder if either of you would like 14 to make a statement before we get down to work on this Guide?
15 What is the name of that union again?
16 VOICE: International Union of Operating Engineers.
17 The feeling I get right now, the subject is mostly health at 18 the nuclear plants. All we have to do with nuclear power 19 plants. .which right now we don't have any that our members 20 are working in, is building lt.
21 After it's built, repaired once in a while, we will 1
22 send one or two men in. So at the present, I won't comment ;
l 23 on this unless he wants to comment on something about this. I 24 Mostly, what we are concerned here is pipeline and 25 pump stations, chemical plants that are built, the hazards
. l 1
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6.03.13 31 LT 1 we have when we are building those plants.
2 So right now, I will just be quiet for a li.ttle 3 while. All right. ,
4 MR. ALEXANDER 2 All right. Yo'u feel fr.ee to say 5 anything you want to at any time during the meeting. Now, 6 we have one more union represented here, the young lady in the 7 back. -
8 I believe you are from one of the unions, aren't you?
9 MS. MAC DONALD: That's correct, I am Lynn 10 MacDonald, I recently joined the Machindsts' Union. I am JI not even sure how many of our members are exposed to low-level 12 radiation at nuclear power plants.
13 I am aware, however, that there are handlers that 14 move radioactive materials, transport materials. One of the 15 . things that concerns me about the NRC giving out Information 16 about effects, long-term, short-term, et cetera, of radiation 17 exposure, is that I understand there is quite a bit of 18 controversy about what is an acceptable level of radiation 19 exposure.
20 If you are promoting one set of data as an 21 acceptable measure, yet there is scientific controversy that 22 perhaps that is not an acceptable level, where do we resolve 23 this dilenma?
24 We don't want to be advocating something that may 25 be incorrect and we don't want to endorse m is inf o rma t io n ACE-FEDERAL REPORTERS, INC. (202)347-3700
6.03.14 32 LT- 1 either that may be coming from a federal agency. Tha t is 2 - what I would like to comment on right now.
3 MR. ALEXANDER: Thank you. That is an interesting 4 point. There is.one branch of the burea'ucracy that can't 5 hide behind the controversy and that's the Nuclear Regulatory 6' Commission.
7 We have to regulate the industry. We have to make 8 a decision one way or another. This is .the limit, you exceed 9 that, you have violated the law.
10 So we just take the light that we have and make
.11 the be st recommendations we can to our Commission and move 12 forward with progre.ss. '
13 But it's not one that, like the. good scientists we 14 would like to be and say, "Well, let's wait a hundred years 15 until we have all the answers." We have .to set limits now.
16 The only. thing we can do is to bring in as much 17 dlf.ferent viewpoint, data, as we can find to help our 18 Commission make the decision.
19 We have a member of the staff who wants to speak.
20 This is Bill Kreger, who is the chief of -the radiological 21 assessments branch in the of fice - that does the licensing 22 of the nuclear power plants.
23 MR. KREGER: All I wanted to do, Bob, with regard 24 to that last comment, was mention that the proposed rulenaking 25 you talked about earlier regarding the occupational exposure ACE-FEDERAL ~ REPORTERS, INC. (2f')347-3700 l
16.03.15 33
'LT l' limits tha't the staff has proposed to the Commission was 2 proposed to be held after, if you will, all the facts .regarding 3 the risk of radiation exposure, or all the f acts that could 4 be assembled in a reasonable time frame were in.
5 Specifically, the staff recommended that the 6 rulemaking hearings on occupational exposure limits not be 7 held until this coming spring because the output'of several 8 1.mportant bodies that have been reviewing all o.f the data that 9 is being collected and reported by a number of groups, 10 including the Mancuso study, the Bross.Natarajan study, the
.11 Rosalie Bertell's work, Cyril Comer's, and Sagan's work 12 and a whole lot of other works, the results of all those 13 studies are being collected together in an analysis by the 14 so-called Commi.ttee on Biological Eff ects of Radiation which 15 is expected to issue its. third report on the relationship
- 16 between radiation exposure and health risk in January of this 17 year.
IS So the basis for our proposals and expected findings 19 on occupational exposure limits.will be, the outcome of that 20 study and a very extensive interagency study being chaired 21 by the Department of Health. Education and Welfare with 22 Pierre La Bosse, as chairman of that Commi.ttee which is coming 23 up with a report to the White House on the risk of low-level 24 radiation exposure, both those inputs analyzing all the data 25 that is currently available will be available before we have ACE-FEDERAL REPORTERS, INC. (202)347-3700
. . , _ . . . . . _ _ . _ . _ - _ _ . . _ _ . . . . , ~. _ . . ._ _. _ ._ ___
4 .
416.03.16 34 LT -1 our rulemaking. l 2 MR. ALEXANDER: Yes, that is an excellent point.
3 There was also a request from the office that does the 4 licensing for the f uel cycle f acilities,' Nuclear Materials 5 Safety and Safeguards Off. ice, requested that we make that same 6 point today.
- 7. ,
That sort of has to do with policymaking. We do 8 anticipate holding.a hearing, a public hearing on this . subject 9 of low-level radiation risk in the spring.
10 We don't propose to issue. this Regulatory Guide
.!! even for comment until af ter this new BEIR report is published-12 and until af ter the hearing has been held to bring to GGGG f u, 13 whatever information that comes to light from that report and 14 from that hearing on the development of the Gulde.
15 So the Guide would reflect the current policy 16 of the NRC as developed af ter those public hearings. Did you 17 have a question?
18 MS. MAC DONALD: Yes, I wanted to ask the composition 19 of your rulemaking and standard se.tting, do you do it similar 20 to OSHA, economic impact statements?
21 MR. ALEXANDER: Yes. I can give you a brief 22 description of our process.
23 I am not an expert on the diff erences between OSHA's 24 procedures and ours. The' only one I know of that Steve Wodka 25' brought to my attention at the meeting he nentioned is, ACE-FEDERAL REPORTERS, INC. (202)347-3700 m v w &+- w- e r'yF 'w T' o-+ +.W -~ 4 wr 16.03.17 35 LT I whereas the NRC has a choice in whether or not to hold public 2 hearings'en a new regulation, I believe Steve told me that OSHA 3 is constrained always to have a hearing on any regulation, 4 and he's nodding yes.
- 5 Other than that, I believe the process is very 6 s im ilar. What we do is, let's take an example of an 7 occupational health' protection standard of which I know about.
S We receive a request from a union or a request from !
l 9 a scientist or perhaps a petition, or perhaps I or one of \
l 10 my colleagues comes up with a problem that we think needs to Ji be addressed in .a regulation, and the NRC staff works together 12 to develop a proposal for the Commission. :
13 This proposal reflects the viewpoint of the 14 standards development people who' carry the ball in the 15 standards development effort.
16 -
The licensing people who take the responsibility 17 for authorizing the use of these materials and systems, the 18 inspection and enforcement people and the legal people, when 19 we finally agree on .what we want to recommend to the 20 Commission, we make a presentation to them in writing, and 21 sometimes In person in a briefing, to publish the regulation 22 for public comment in the Federal Register.
23 If the Commission is willing, we do that. Very ,
24 often, particularly if there is any controversy associated 25 with it, we send cop.es of the proposed rule to our list of ACE-FEDERAL REPORTERS, INC. (202)347-3700
- 6.03.18 36 LT 1 affected licensees.
2 Incidentally, we have over 9000 different 3 licensees, so that is not a trivial task sometimes in the 4 mailing.
5 Then, af ter the pubile comments are received and 6 evaluated, an analysis is made and each one is dealt with 7 individually 'and a written rationale is developed as to why 8 each comment was either accepted or re jected and presented 9 back to the Commission with a request to publish the rule 10 in the Federal Register as a regulation. As a law.
JJ Now, in my experience and I believe.it's true, 12 some of you who have been here longer than I have can correct ,
1.3 me if I am wrong, but I believe we have never gone through 14' the hearing process for an occupational health protection 15 standard.
16 I- believe that the one that we are talking about 17 this spring will be the first one.
18 MS. MAC DONALD: The basis for my question. I 19 didn't hear correctly, I thought the sta.ff member earlier 20 was just saying that government was talking to government 21 In developing the standards and I was hoping there would be 22 a hearing, an outside information hearing.
23 MR. ALEXANDER: I am glad you raised that question 24 because we certainly don't mean to leave that impression.
25 As a . matter of f act, even though our branch has not held a ACE-FEDERAL REPORTERS, INC. (202)347-3700
16.03.19 37 LT 1 public hearing'before, we have and normally do go to great 2 lengths. to bring in public opinion on what we are doing.
3 That is exactly what this 1 meeting is about today.
- 4. We do our best to maintain a neutral position and to represent !
5 all aspects of our American society who.are interested in 6 occupational health protection from radiation.
7 Bill Kreger.
8 ,
MR. KREGER: Bob, I don't know if I left the wrong 1 9 impression, but the Biological Eff ects of Radiation Committee, 10 of Ionizing Radiation Committee, is not a government body.
.11 It was convened by the National Academy of Sciences'-
12 National Research Council. But it's made up of almost entirely 1.3 people outside of the government. That is the body which is 14 looked to by both government and international bodies as the 15 group that is collecting the most broadly accurate and 16 representative viewpoint on the risks of radiation.
17 And the report of that committee, Commi.ttee of 18 University Scientists, industrial sc ientists, international 19 scientists of high repute, it's the report of that co mmittae 20 that is going to be input to the various standard setting 21 bodies regarding occupational exposure limits.
22 MR.. ALEXANDER 2 Well, I believe it's time now to 23 declare the introductory period to have closed. I doubt if 24 many of us have gone through longer ones.
25 But we have had good participation and I think we ACE-FEDERAL REFORTERS, INC. (202)347-3700
38 6.03.20 LT 1 are all a little' wiser as a result of listening to each other.
2 I think it's time f or a coff ee break. Now, co f f ee 3 break, as all. things at the Nuclear Regulatory Commission 4 is not easy. There are two ways we can'do it.
5 We can all sign an which will take up all of the rest 6 of the morning signing in in order to get to the cafeteria 7 or we can send out for the coffee.
8 And take a 10-mLnute break and maybe by the time 9 we reassemble here, the coff ee will be here.
10 We would have furnished the coff ee except that I
.11 would have had to pay for it personally, and objecting to that, 12 we deelded to go dutch and I would like a showing of hands 13 from everybody who wants coff ee so we .will know how many 14 cups to order.
15 (Brief rece ss. )
16 G734y 17 18 19 20 21 22 23 24 l
25 i
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4 w 16.05.1- 39 jon 1 MR. ALEXANDER: The decision has been made. It may 2 not have been very popular, since some people have to leave at ;
3 'l:30, to go ahead and work through the lunch hour. If anyone l 4 starves to death, we will bring something down to you, I guess.
5 I would like to introduce you now to Alan Roecklein, 6 who will conduct the balance of the meeting.
7 . Thank you.
8 MR. ROECKLEIN Thank you, Bob.
9 The first. thing I would like to do is pass around a 2 10 sign-up sheet so we have some idea of who you are so .we can '
.11 k eep in touch with you.. If there is any f ollow-up material to 12 this meeting, we will try to get cop.ies to you.
13 In the correspondence we included copies of art agende 14 for today, a copy ~of Reg Guide 8.13, and a last o.f questions.
15 We will be more or less using that material as we carry on this 16 discussion.
17 So if there is anybody who doesn't have any of those, 18 . let.me pass them out now. I will pass out three stacks, and 19 take what you don't have.
20 This is the agenda, and some additional copies of 21 Reg Guide 8.13, and then our list of questions.
22 I think it is clear that I have more questions for 23 you than ans.wers.
24 My objective at this point is to try to focus our 25 attention on the. format of a possible reg guide on the subject ACE-FEDERAL REPORTERS, INC. (202)347-3700
^6.05.2 40 Jon 1 of risks from occupationn1 radiation exposure.
2 The first question I had here on my notes is whether 3 we should consider the desdrability of such a guide. i 4 I think that is an important question. We have heard 5 a lot of comment on It already. There may be somebody else who 6 would like to say something to that.
7 I suspect it was f airly well exhausted.
8 If not, we.will look on the agenda to the first item, 9 the suggested f ormat for an instructional instrument.
10 We are looking initially at 8.13 as a model, since i
. .11 it seems to have been effective in the field. At least some 12 people say It has been eff ective. ,
13 There are two parts to 8.13. The first part is the 14 usual reg guide format that refers users to the appendix and 15 the aopendix becomes the . actual instructional material.
16 It is what the trainee says, hears, whatever.
17 What we are considering doing wculd 'li.st or include 18 material in that appendix.
19 Again,. this is the instructional material. It is 20 what we wo.uld hope would be useful to the trainee.
21 This is where I would like to get your reaetions.
I 22 will run down' a list of major topics which have been suggested <
23 whleh we are considering, and give you a chance to comment on 24 their appropriatene.ss.
25 We would begin, I think, with a definition of risk, ACE-FEDERAL REPORTERSr INC. (202)347-3700 I
16.05.3 41 Jon 'l' discuss what . the biological effects are 3from lonizing 2 radiatlon, as'wellias they are known, including some of.the l 3 types of cancer that might be caused by radiatlen.
4 We would attempt to make a quantitative estimate of
'5 these risks.
6- There has been some work done by the'ICRP'and t'he 7 BEIR Report which attempts:to tack numbers on to the risk.
8 We would go beyond that and try to provide some 9 comparisons. There are se veral po ssible comparisons that .might 10 be useful to the worker in the field. One would be a' ,
.11 comparison to the. radiation risks to other kinds of health 12 hazards. Smoking has been mentioned.
13 The normal rates of cancer in the population. -
14 We would compare ' radiation ris ks to o.ccupation&1 i 15 risks in other industries.
16 Some studies have' been done, most . notably a recent
- 17 study in Canada whlch looks at various types of energy systems, _
13 and also compares injury risks and accident . risks from nuclear 19 to mining, construction, and manuf acturing. Some of these 20 numbers might be useful to the worker.
21 We thought that a comparison of the accident rates in l 22 the nuclear industry to other kinds of occupational fields 9 ,
23 would be useful. Especially since it has been relatively low.
24 At that point it would be appropriate,. I think, to 25 look at -- to discuss what the NRC radiation exposure limits ACE-FEDERAL REPORTERS, INC. (202)347-3700
16,05.4 42 jon 1 are and how they are established, outline as best we could 2 the kinds of research, the kinds of experiences that we have 3 had .which lead the NRC to establish limits, what they are 4 based on, and an explanation of the ALARA concepts make it 5 clear. to th e worker that , in addition to limits to his 6 exposure, there is a guiding principle which attempts to keep 7 exposures as low as reasonably achievable.
8 We have data on what the normal exposures are in the 9 industry. I. think it would be helpful to include that in an lo Instructional guide.
.11 Again, at that point we might consider comparing the
- 12 average exposure to normal background, to the kinds of 13 exposure that one recelves in medical applications.
14 As has been mentioned, there have been criticisms of 15 the limits. They are too hight they are tco low.
16 Certainly the worker is aware of that, and I think we 17 want to consider including some of the arguments that are for 13 or against changing the limits.
19 I am not sure at this point how we might do that.
20 As in 8.13, there is a section which discusses what 21 the worker's rights are, what his options are, suggestions of 22 some alter. natives to accepting the risk of radiation exposure.
23 We night consider developing some information on 24 that si.milar to 8.13.
25 Fina ll y, I think it would be useful if we could list ACE-FEDERAL REPORTERS, INC. (202)347-3700
- 16.05.5 43 Jon I some additional sources of information on risk that the worker-2 could consult as a reference for him.
3- That is a' rough outline. I think you will see that 4 that pretty much follows the sequence of. questions which we 5 developed.
6 I would like to stop there and see whether there are 7 any comments about the general content or the topics that we 8 have Antluded.
9 MR. ALEXANDER: Do you think a question and answer 10 approach is suitable for this?
.11 MR. SHOOP On question.and answer, the Fundamentals-12 of Radiatlon. It is an old AEC publication. I haven't seen one 13 in years. But I think the format in that was a question and 14 answer type format.
15 I know we used this with our members, the 16 ,lnternational itself, and some of our employers also used it 17 with our members.
18 This is one way.
19 The ALARA concept, the way you have it laid out there 20 is a good ,way, too, and N13 is also good.
21 The Fundamentals of Radiation was written in laymen's 22 language, which our members are. It was not very difficult.
23 Maybe this approach is the best, as just a suggestion. I have 24 really no preference. I know it worked. It was successful 25 because we used it and some of our employers also used it.
ACE-FEDERAL REPORTERS, INC. (202)347-3700
. .6 6.05.6 su jon 1 MR. ROECKLEIN: That question concerned the format, 2 what that might be.
3 There are other possibilities. I am really 4 Interested now in whether we have left anything out, whether 5 there are other. things you think might be appropriate as a 6 part of the guide, general topics.
7 MR. ALEXANDER
- What,all different approaches did y~ou 8 consider?
9 MR. ROECKLEIN: Well, the first option was a text 10 s imilar to 8.13, .whi-ch would be given to the trainee. I t wo uld
.! ! require f airly good reading ability, I think, and an interest.
12 It might. require an instructor to do some interpretive work.
13 A second was the question and answer format which you 14 have mentioned. I felt that had the same advantages of a text 15 except it tends to focus attention on the central ideas, the 16 things you want to get acro.ss.
17 Another possibility was a programmed self-study 18 document to be given to each worker, a document which would 19 Quide hlm through some mater.ial, and periodically test him on 20 his understanding of the material. ;
21 That is not dependent in any way on an instructor, 22 although usually there is an instructor around for ,uestions.
23 You kind of have to assume the worker is going to do it, 24 however.
25 Yes, sir?
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- 6.05.7 45 Jon i . VOICE Yes on the format. I think question' and 2 answer is a very good way to do it. We do a lot of stuff in i 3 question and answer.
4 But that does not.mean that you should not have an 5 appendix where more careful answers -can be given, because if 6 you are going to put it in everyday lanugage, you are golng to 7 miss a lot of detail. Some of uit is going to be very 'important 8 detail.
9 MR. ROECKLEIN4 Sure.
10 We.11, s e e , we are talking now about the structure
.11 of the appendix which would b1 the material that would be 12 glven out to the trainee. .
^
13 There is a fourth option. That would be an 14 audlo-visual presentation, a video tape of some sort, po ssibly 15 something that we could do in the NRC, or encourage industry to 16 develop.
17 .Dals could be either as the appendix or as the 18 supplement to the appendix.
19 Bob, do we want to show . that video tape at this 20 point?
21 MR. ALEXANDER: Yes. That is a good idea.
22 MR. ROECKLEIN: I think coffee is here. Why don't we 23 take a minute and get our co.ff ee.
- 24. (pause.)
25 : VOICE: It seems to me we should have two booklets.
ACE-FEDERAL REPORTERS, INC. (202)347-3700
$ 16. 05. 8 ' 46
~jo n l' or a booklet with a pref ace to it that has all the questions <
2 ans wered that occur. Ln people's minds.
3 If you are not satisfied with the answer that is 4 down under there, you should have further reference to 5 some placa you can go.
6 MR. ROECKLEINs. Yes. That is a good point, I think.
7- VOICE: You mentloned your f.irst introduction here 8 about what is meant as a risk or what is meant --- or what 9 would be a risk. Right now we are discussing the making of a 10 booklet [ Now we are -- from what we understand, .the first
.11 question wast what is meant by a risk? And we are waiting ~for 12 that. -
4 13 MR. ROECKLEIN So am I.
14 VOICE: Before we decide tJue form, whether it be a
/
6~D 15 three-page book or 10-page book or television program, we~first 16 have to decide what the material and scope o.f .the material 17 that is going to be In there is .before we can decide the shape 18 we put lt in.
19 You started out, as John pointed out, by discussing 20 the vario us approaches to Question Number 1. I think we should 21 continue to do that, going down each of. the questions. Then we 22 will know how much material has to go in that booklet. Then we 23 can. .dec ide the format.
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el6.06.1- 47 i
jon- 1 MR. ROECKLEIN3 Okay. Khat I ran through was a 2 'brief outline of all of the topics that we would consider being 3 included in this guide. The list of questions that I sent you 4 was just a possible formati of course, 1ncluding the answers, 5 as an appendix to the guide.
6 VOICE: We know the questions. We would like to hear 7 your answers. How are you going to approach it?
8 MR. ROECKLEIN: As I said, I have more questions than 9 answers at.this point.
10 I wish I had answers to all those questions. We are 1
.11 working, but haven't gotten too f ar yat.
12 As was pointed out, we are going to have pubile 13 hearings soon, and there ls another report from, I guess it 14 is the BEIR Committee, .on - this subject. Until those are out.
15 we won't know what the answers are.
16 VolCE: I suppose that is true of what your limits 17 are and.your standards are, but there are.many questions in 18 here that are directly related to the layman worker. l 19 MR. ROECKLEIN2 Yes.
20 VOICE: This is what we are after, really. When you 21 people decide which scientist is correct, we are going to have 22 to eventually have faith in someone. So we are after the basic 23 q ue stions .
24 How much risk dose to the worker at the menent is 25 understood to be taken?
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48
.06.2' Jon 1 Once you know what that risk is, once .you tell us -
2 what .that risk is, he has a choice; he can take that risk or ;
3 not. ,
4 By the way, that is one of your questions. ,
5 MR. ROECKLEIN I agram with you. What you are 6 saying is, at'least those questions are appropriate to this 7 document we are considering.
8 VOICE 2 Right.
9 MR. SH00P2 I have got a question, Al. This is 10 just on risk. Risk asse.ssment or risk at work.
.11 Looking through..this, .a lot of this is given at the 12 HP indoctrination course. They are all over the lot. But it 13 should be a supplementary thing, and not doing the same thing.
Maybe -- mercif ully it should be kept short'. I have 14 15 found reactions of our members, even taking the HP course, an 16 eight-hour course, it is almost valueless. He has gotten 17 nothing about it.
18 Yes, he can pass a test and you are certified and <
19 know all about it. He doesn't even know how to spell it. I 20 think we ought to keep this in mind. ,
21 Maybe we are talking about some of the same - things. j 22 Some of.this should be addressed maybe in HP indoctrination l i
23 rather than in risk. 1 24 MR. ROECKLEIN2 As I see it, we require radiation l 25 protection training at all licensees at this point. What we 1
ACE-FEDERAL REPORTERS, INC. (202)347-3700
16.06.3 49 jon 1. are considering here is that for part of that required l 2 traihing, some Indicat'lon of what we would consider to be an 3 acceptable level'of training, aceeptable content. ,
That part I
4 relatlng to the risk from ' radiation.
l 5 So we are elaborating on only part of that training.
6 MR. ALEXANDER: Let me mention something on that, 7 too,. Paul.
8 We - 1 reg guide on what we think a e -- it 9 is on training.
10 MR . S HOOP . I think that is a real good pro. ject, Bob, 4
.11 because that is needed.
12 MR. ALEXANDER ' Thank you.
-13 What we can do, and the note I am making to myself 14 here, is to, well, Bell, si.tting behind you in the gray suit, 15 and one of the f ellows in the offices, get them t.o chec4 out 16 your point and see if there. are any answers to these questions 17 that really should bellncluded in an appendix we have to that 18 guide which lists all the topics .we think should be addressed ;
19 in the workers' trainlng, and perhaps in that way shorten this 20 thing.
21 We can do that. That is what.you are after, isn't 22 it?
23 MR. SH00P2 If you are. talking about the HP 24 Indoctrination, essentially what you are going to have in the 25 guide, the guide can be mu,ch shorter be.eJse you are going to ACE-FEDERAL REPORTERS, INC. (202)347-3700
$1600604 50 Jon l'~ cover a -lot' of these other topics.
2 I can see from some of .the ' questions that they would.
3 naturally come up in the indoctrinatlon course, or should.
4 MR. ALEXANDER: Okay. We can do that.
.5' MR. ROECKLEIN There has been some concern that 6 these questions don't.get brought up'in' indoctrination courses.
7- If this .is true,.this would be one of the reasons why we~ would-8 want to develop this gulde. ,
9 Does that make sense?'
. 10 MR. ALEXANDER: Sae, what I am saying, A1, is that ,
.I l there might be some tople here, or more than one, which you 12 have in this guida, like that. which Jack doesn't .have in his.
- 13 We might transfer fr:m yours to his in order to '
14 make this one a li.ttle shorter. We can look at that as a 15 possibility.
16 -MR. ROECKLEIN: S ur e .
17 MR. SHOOP: My th inkin g, t oo , at this point , Al --
18 and I have nothing in advance on it -- 1s, okay, the 19' indoctrination,' we want to accomplish one set of. goals.- With 20 the risk, we want to accomplish another sat of goals.
21 Maybe' with the risk we want the guy th?t's a 22 nonnuclear station employee, where he 'is thinking, "There is 23 a possibilit[I might' have to go there. . I am not really 24 interested in an~ indoctrination course'because I.might not go l 25 the re, sut if I go there, what am I getting into?"
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Jon .1- This is what the reg guide on risk could addrass 2 itself to. l 3 In addition to the reactor employee, the nonreactor 4 employee that might be subject to go there, or one of our i 5 members from the building trades who are not pe'rmanently 6 assigned there.
7 MR. ROECKLEIN: I see your point.
Is there comment 8 over that?
9 VOICE: What I was going to ask is the clout. Now :
10 you put the guides out. 'Last week in the daily news from the
.11 NRC came a report that Indian Point 2 wasn't meeting all the 12 standards and what. not. They got a bad rating from the NRC.
13 Now, the men that. worked there, they s ee this, and no 14 matter how good your g0ide is or any. thing else, if there is no 15 clout, it loses its whole purpose.
16 MR. ROECKLEIN: It is not clear to me what you mean 17 by clout.
13 VOICE: Well, in giving all these risks and 19 everything, if the summation, if they are not followed, these 20 steps will be taken by the nuclear -- what steps?
21 MR. ROECKLEIN: Bob, would you like to explain what 22 the Regulatory position is, what our enforcement clout is in 23 this case?
24 MR. JOY By the way, we are not shooting you down.
25 This is nothing personal. !
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16.06.6 52 Jon i MR. ROECKLEIN2 I understand.
2 MR. ALEXANDER
- We Iro k at this guide as a train'ng 3 aid, of course. The clout is in part 19 where the licensee 4 is required by the regulation to_do a job of training that is 5 commensurate with the risk.
6 Once we put out a guide, an instructional aid in the 7 form of regulatory guide, then that licensee has to e'ther use 8 that guide or he has got to come up with anothe.r one that he 9 can convince our license reviewer is .just as scod.
10 So the clout is in the regulation. 1
.11 A guide has a lot of influence. It is true that.you 12 don't have to comply with it, but you do have to do something 13 that is just as good.
14 MR. JOY: I understand the HP indoctrination..before 15 anybody goes into a nuclear installation, the problem with j 16 the indoctrination at the present moment, I think it raises 17 as many questions as it answers.
18 When somecody is ready to go in there who has never l 19 heen there before, or perhaps was there a couple years age out l
20 had not paid too much attention to it, when they go into this 21 indoctrination period, when they walk out of there they have 22 the questions to ask af ter they analyze it. They just don't 23 have time in an eight-hour session. i 24 I think it creates a lot of difficulty.
Somewhere in a guide, if the guide can be given to 25
' ACE-FEDERAL REPORTERS, INC. (202)347-3700
1 4 e
>l 6. 06. 7 53 Jon 1 every nuclear or radiation worker, let him look at it. Let 2 him take it home. Let him see what it is.
3 The possibility, as you indicated, Paul, some day I 4 might be sent there, but I haven't been told I am going there 5 yet, let him get that guide.
6 Let him understand that guide. Let him have the 7 questions before he gets into the meeting with the health S physicist so when he gets there he knows what questions he 9 wants to askt not as he walks into the HP indoctrination:
10 here it is.
.11 Now, before he gets a chance to read it, the 12 lndoctrination is going on. He hasn't had a chance to analyze 13 what questions and fears he has and doesn't really know what 14 the hell he is talking about.
15 These are the problems the companies have to 16 understand.
17 Maybe there is ne m.ajor problem at the present time.
18 But it is going to come.
19 What is going on today? All we want them to do is 20 to have the proper orientation so when they go thelr questions 21 are answered and they can analyze them in a simple way.
22 They are not scientists. They never will be 23 scientists. They are not physicists and never will be 24 phys ic is ts . They are not health physicists. They are just 25 average workers.
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116.06.8 54 Jon i I don't know how to make that simpler.
2 We can go to format. What is the best format?
3 Question and answer, by all means. ,
You are going to anssier 4 practically every question on their minds and ask the question 5 they are afraid to ask because many times in a mass group 6 people are afrald to get up and ask the questions they would 7 like to ask.
8 But just get that information to them.
9 'Get back to your original questions what is the risk?
10 Simple language s what is the risk? What is the risk of so much
.11 radiation, low level? That's it.
12 Maybe I am oversimplifying it.
l 13 MR. ROECKLEIN: I agr.se with you. Yes, sir.
14 VOICE: When you discuss the question of risk, I 15 assume you will make tha comparison of risk in the nuclear 16 fleid as opposed to risks in other occupations, and not simply 17 as I noticed in your guide, the risk of working in a plant 18 compared to standing next to a granite wall.
19 We stay right within the framework of radiation and
]
20 cancer. I 21 I wonder whether you will point out the risks of 22 worklng in a flour mill, the possibilities of developing 23 another fatal disease.
24 MR. ROECKLEIN: Yes, I think so. We looked at three 25 possible comparisons. Comparisons to -- well, let me --
ACE-FEDERAL REPORTERS, INC. (202)347-3700
- 16.06.9 35 Jon 1 comparison of'. radiation risk to other health' hazards, like ,
2 smoking, starding next to a granite well perhaps. Comparison l' 3' to other kinds of occupational risks in other industr'ies.
And l 4 then a comparlson of accident rates atz nuclear f acilities 5 compared to other f acilities. 3 6 So I think we are aware that that would be a very.
7 important question.
8 VOICE: The only' reason I say~that is that I am 9 .convinc.ed no one is afraid of radiation. Everyone fears-10 cancer.
.11 I think there is a,significant difference here. I 12 think we --'I think what we are talking about all the time is 13 cancer to everybody. We are no't talking radiation. We always 14 end up talking cancer.
15 I think some distinction should 'be drawn.
16 MR . SHOOP : This is our observation of the root of i
17' .the problem. The questions we get all deal with cancer, 'not i
18 the violent death. They are not interested in this. But what 19 is the relationship between cancer and my cumulative or-life 20 exposure.
21 One thing, as a union representative, I-have a hard 22 time getting cumulative exposures. It is just not made ;
23 available.
24 They give me the Mickey ~ Mouse: "Get your memt:er to 25' request this and he can give it to you." "It is not practical."
i ACE-FEDERAL' REPORTERS, INC. (202)347-3700
16.06.10 56 jon 1 MR. ROECKLEIN: You say you are having difficulty 2 getting your. exposure, or.your workers' exposure?
3 MR. SHo0P: our members' exposure.
4 So the' union representative wa'nts .to represent his 5 members, but he has a hard time getting the cumulative dose.
6 .This is what you are relating to, cancer, cumulative exposure.
7 This is, really, I think, what they are talking about 8 when they are talking about risk.
9 MR. ROECKLEIN: Yes.
10 MR; SHOOP Electricians. You are talking risk to
.11 an average electrician, you are talking electrocution. And I 12 think for the radiation worker you are talking cancer.
13- MS. MAC DONALD: Yes. I wonder if you wouldn't be 14 missing the point by comparing saf ety or health hazards by 15 different industries to radiation.
16 Perhaps you would..want to compare different kinds of 17 exposure tc radiation at different kinds of jobs rather than 18 comparing the risk to a nuclear plant employee to a flour mill 19 employee.
20 I am not sure you are comparing th3 same thing. ,
21 VOICE: But there are other occupations which are not 22 related to radiation that do cause cancer. Particularly in the 23 Chemical Workers Union.
24 MS. MAC DONALD: But this guideline is for radiation.
25 VOICE: I know. But, you s ee , there is so much ACE-FEDERAL REPORTERS, INC. (202)347-3700
. . ~ . . -. _ . . . . .. . . . - _ ___
I6.0c.11 57 Jon 1 controversy going on .now our memoers don't know who to 2 believe.
3 MS. MAC. DONALD: Right.
4 VOICE: That is why we have said. the government 5 should take a position.
6 MS. MAC DONALD: Right.
7 V0 ICE:
There is no occupation, despite my idealistic 8 friend, that is so safe and pure that nobody is going to get 9 hurt.
10 If you are going to work, you take a risk. If you
.11 live, you take a risk.
12 We would like to be able to tell our members what 13 the degree of risk is. Simple as that. Then he has to decide 14 whether he wants to work in that plant or not.
15 MS. MAC DONALD: Yes, but I would like to -- I mean 16 you get some men that are skilled, they don't have a lot of 17 options whether to stay there or work in a flour mill. But 18 they may have an opportunity --
19 VOICE: But we are talking about skilled workers.
20 Most workers in the nuclear power industry are skilled workers.
21 MS. MAC DONALD: I know. So they are not going to 22 wal k away --
23 VOICE: They are machiners and riggers and 24 operators. They can, believe it or not, work elsewhere. Even 25 within the same union.
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l 616.06.12 58 jon i MR. ROECKLEIN: Yes, sir.
2 VOICE 2 When I asked that question and we asked about 3 getting back on the subject, what is meant as a risk, I'd ask 4 in.co mparison, as far as radiation and 1ndustry today, when you i
5 people as scientists and we the laymen come up w.ith' a decision 6 .on what a risk is really, against what?
7 We talk about granite walls. We talk about an auto 8 industry. A person rolls windows up when they are driving the 9 car and they are' spewing fumes all over the area. rights is 10 that a comparisor. to radiation? .Will it have an effect?
11 We will talk about the word cancer, which everybody 12 has e fear of.
13 Of course, again, we say what is causing this. No 14 one can rea.11y come up with an answer. I haven't heard it.
15 We read a lot in the media and hear from.the news 16 people. But we say what is the risk, in comparison to what'?
17 Are you people prepared to say radiation in 13 comparison to whatever the subject-matter is, thac is spewing 19 out chemicals, this is where the worker will be aff ected and 20 this is what we want to know and this is what the layman is 21 asking.
22 If I am swimming in the waters and at is spewing 23 out PSC and they are saying is this going to a.ff ect me more 24 than radiation or what, this is the questions the workers ask i
25 and we like the answers.
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16.06.13 59 1 Jon 1 When you are setting up a booklet and say how shall
, 2 it read, it shall read so the layman can understand it and !
3 understand the makeup of it.
4 So f ar all we have been doing .is bouncing this off 5 the wall and saying how should it be set up in the'index and 6 how should we present it.
7 We are presenting something to you people that the 8 average worker is asking.
9 When we go into these plants, how are we affected?
10 And we want the answers and we want a straight answer.
11 Whether it takes 20 years for me to get cancer or some pregnant 12 woman winds up with a child that is deformed. .we would like to 15 know that, t oo .
~
14 But if the case may be where you people are saying 15 this is safe, it is a safe operation, because every day of the 16 week you are affected by more so, this is beautifult we would 17 like to know that.
18 We realize we have to make prograss, as Bob has said.
19 20 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC. (202)347-3700
c 60 i.07.1 cmw 1 MR. ALEX ANDER s one of the comparisons of.these 2 questions we have found, we have already done some studies 3 like this for the Commi.ssion, and you can do a pretty good 4 job of comparing the rlsK. the cancer risk from occupational 5 radiation exposure. with accidants.
6 But a lot of people don't like that.
7 There are some differences between cancer that you 8 might get after 20 years of exposure, and an accident which 9 kills you instantly.
10 So although we can do a good job of comparison and
.11 will.go ahead and do it in this Gulde, that won't set too well 12 with e verybody.
13 VOICE Let me interrupt you, Bob.
14 I don't mean specifica.11y an answer.
15 Let's talk about the Federal Government standards on 16 asbestos.
17 MR. ALEXANDER: That is what I am ge tting to.
18 So if you go with industrial disease and try to make 19 a comparison, you can't find the data.
20 We struggled and struggled Steve McGuire did that 21 for us. He struggled and struggled trying to find data. .
22 And finally he came up with a ILttle bit we could at 23 use , but it just -- the data just aren't there,with a ccidents.
24 So many of these things, diseases that are caused by 25 such things as asbestos are caused by other things, too.
ACE-FEDERAL REPORTERS, INC. (202)347-3700
c
$ 16. 07, 61 cmw- 1. So any number that'you have for incidence of some-2 industrial disease that's been reported .is going to be small 3 compared probably - probably small compared with how many 4 ~ have actually. occurred, because all those others were never 5 reported. ,
6 people dropped .out of the industry, went into: another 7 Industry, came.down with the disease ' -and it 8 was never reported.
9 MS. MAC. DONALD I don't understand what kind of 10 .information you would be giving to a worker if you're comparing
.11 asbestos and radiation and lead.
12 It seems to me that it would be . a lot more useful to 13 know the levels of exposures of different kinds of jobs in one 14 plant.
15 That would be much more useful information for 16 someone to read that to say, .well, if I were working ln 17 asbestos.
18 MR. JOY: I understand what you're saying, but the 19 one thing the brother from New York, chemicals, this morning 20 touched on, he's talking about a risk frequency.
21 There's no such. animal. But everybo'dy has to 22 understand' the risk is there.
23 There is a risk. And to compare that with.the risk
- 24. In other industries. I understand your point but you can't 25 get around this to a worker. You're saying to a worker, he ACE-FEDERAL REPORTERS, INC. (202)347-3700
.62-307.3
-emw I ' wants to be told . that. this is -risk fr ee.- He can't be told It's impossible . I don't care what they do in the 2 that.
3 NRC;or.anything.else.
4
- On the other hand, there is no industry that is r is k f r.ee . . So what you're doing is drawing a comparison that 5
Then you're 6 every industry has a risk, ' including this one.
7 comparing the risks to other industries.
8 MR. ROECKLEIN: This is what we intended.
- 9 VOICE: As a matter of fact..on this page you have 10 a paragraph that says'in 50 years of medical evidence you
.11 haven't f ound any . clinically observable damage. Is that a true 12 statement? There has been no clinical evidence, medical 13 evidence?
14 MR. ALEXANDER 2 No, there have 'been accidents that 15 have taken the lives --
He qaddlied it. If the exposure level is 16 . VOICE:
17 maintained.
18 MR. ROECKLEIN: That's true.
19 VOICE: If a person turns up with cancer after 20 ,
20 years of exposure, there is no way to prove --
21 VOICE 2 This says no clinical proof.
VOICE: That is what I am saying.
There is no 22 clinical proof that the cancer came from radiation. The cancer 23 24 may have occurred, but whether it came from radiation is a 25 statistical question. That is different.
' ACE-FEDERAL REPORTERS, INC. (202)347-3700 ,
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16.07.4 63 cmw 'l VOICE: . Could I ta'k?
2 MR. ROECKLEIN: Sure, that is what you're here for.
3 VOICE: All right, you gave us a three-page 4 memorandum here, the way I s ee it. Are you going to talk on 5 No. 1.first, because we're going all over the lot here? l 6 Eve.rybody talked about No. 7. It says if I receive 7 a radiation exposure, _ does that mean I am golng to get cancer?
8 Are we talking about No. 7? We are all over the 9 lot here.
10 I want to ask a question on No. 1. Where are we?
. 11 MR. ROECKLEIN2 What I was interested in initially 12 was what klnd of format would make the best possible .
13 instruction for the worker.
14 I think it's marvelous that you have all had a lot 15 to say.
16 VOICE: Oh, you want to hear that. All right,'then,
~
17 go all over the lot. ,
18 MR. ROECKLEIN: If you want to say something about 19 a question, please go ahead.
20 VOICE: If you're going to go by this as a 21 guideline to talk on, right, all right, there is No. 1, what ,
22 ls meant by risk.
23 Somebody was talking about No. 7. That's what I'm --
24 are we on No. 17 Risk? Where does the risk really begin as 25 - far as radiation levels, exposure levels, you know? 1 l
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2 In.other words, what_is meant by risk? Where does 3 the. risk really begin as far as exposure levels?
~4 MR. ROECKLEIN: The prevalent ' theory, there is the
- _I 5 linear hypothesis, meaning it doesn't matter how much radiation l 6 you get, there is tome potential damage. The more you get, 7 the more the damage. l 8 Correct me again if' I am. wrong, but our limits are 9 based on data which is at high dose' rates, large exposures, 10 where we do see some results.
.11 We are operating. down here, where all you have is 12 statistical data and not enough' people to make any- real 13 conclusions.
14 We make the assumption that it doesn't matter how ,
15 low your exposure gets, there will be some -statistical, some 16 . increased probability of risk, of damage, of cancer.
17 VOICE That statement on the risk, that is quest h g _
18 exactly what it means.
19 The risk,.now, against what? Now -you have said 20 if you get a high or low level of radiation, no one has really.
21 come up and spelled it out. Okay.
22 -
So you say where do you compare, what ls the 23 comparison? It cannot be against. radiation. You have that 24 subject.
J 25 So your subject'is radiation against what, so-you do ,
I
< U ACE-FEDERAL REPORTERS, INC. (202)347-3700
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> 4 316.07.'6- 65 cmw I not have enough history to say. You talk about accidents.
2 But you have to have a comparison test. So.whereLdo you 3 test it?. Do. you test -it on irradiation on an animal or _ do ,
4 you' blow smoke on an anlmal's hide and. say, . okay, tha t 'is
~
5 comparison to radiation on the rems that you receive in a 6 nuclear! plant.
"7 This is what-the layman.ls asking.
3 So far we have not receivedLthat in the time we -
9 have spent discussing.this.
a 10 Where are we going to compare, comparison against j
.11 the radiation?
12 MR..SHDOPs. To get us back in line, at least I.
i 13 think -- ,
14- MR. ROECKLEIN:- That is a legitimate question. .I 15 don't have the answer.
i 16 MR. ALEXANDER: The answer is that where we deal 17 in the question, I can't find it right now, that deals with 18 comparison, we haven't actually worded .these answers .yet, 19 but I think .we will probably do something like saying that out-20 of 100,000 workers getting five rems per year every year, an 21 ' estimated number, X, will contract radiat. ion-induced cancer and 22 die of it according to our best estimate.
23 On the other hand, in the asbestos industry, people 24- who are exposed to levels that OSHA allows, out of 100,000 25 the following number will get cancer.
ACE-FEDERAL REPORTERS, INC.-(202)347-3700
@,07.7 66 cmw I of the people who -mine in the uranium mines, still
- 2. a larger number will get cancer according to the best .
3 Information we have, ,
4 So you're . talking about a grou'p of 100,000 workers
'i 5 and a certain number dying of cancer due to their exposure at.
6 work, comparing the industry that they are. working in with the 7 industry that their. brother-in-law works in. .
8 VOICEJ Are you talking --
9 MR. ALEXANDER: And try to draw that kind of 10 . perspective.
,11 VOICE: Are you talking in those, though, Bob, in 12 general figures, per se, or compared to the population as a 13 whole?
14 MR. ALEXANDER: Compared to the population as a No, not the population as a whole. You mean including 15 whole?
16 women and. children?
17 VOICE: Yes.
18 MR. ALEXANDER: No, we are going to just talk about 19 workers.
20 VOICE: Let me say, you're goi.ng to say that in the ,
1 21 . nuclear industry, for every 1.00,000 workers, 36 of them are
~
22 going to end.up with cancer.
23 Now, if you don't have some indication of how many of those people would have got cancer if they weren't in'the 24 25 nuclear industry, it really isn't a valid comparison.
1 l
. ACE-FEDERAL REPORTERS, INC. (202)347-3700
'6.07.8 67 cmw I .MR. ALEXANDER: Oh, you're talking about the 2 so-called natural incidence of cancer.
3 VOICE: Right. ,
4 MR. ALEXANDER 2 Yes. Alan's al' ready mentioned that ,
5 we are going to put some of that informat ion in. We can 6 work that into the questions.
7 MR. ROECKLEIN: We'have som' ista from the American 8 Cancer Soclety.
9 VOICE 8 I. think' we have got to realize, I don't 10 know how to say it, but the number of people at the level of 11 intelligence of a 12-year-old or 15-year-old.
12 Now, when the average worker gets this, it has to be 13 interpreted by the lowest level of intelligence there.
14 Some people can't understand rems. They can't 15 understand the diff erent technical terminologies.
16 So the comparison would be not in relation to 17 asbestos, not in relation to cigarettes, but in order for a 18 man to understand what he copes with every day in relation to 19 the radiation.
20 I think this is where the comparison avenue should 21 be gone into, not because of asbestos so much and this so much.
22 But the nan understands it at his level of intelligence of 23 how to interpret what rems mean, because the average person 1
24 today that works as a mechanic, or the labor pool today, no 25 matter how many classes you have, no matter how. many books you l
l I
ACE-FEDERAL REPORTERS, INC. (202)347-3700
l 16.07.9 68 $
cmw print, if it doesn't- get down to his level of intelligence, I
2 I' don't think it's going to do any good.
3 MR. ROECKLEIN: You're, suggesting that we retain 4 comparing risk, cancer risks, to other kinds of. things, 5 automobile a ccidents, f or example? Smoking?
1 6 . VOICE: Yes. Not in the vein of, you're taking a 7 less risk, but this .is what life is all about. .W e're talking l 8 about five rems. Well, five rems would be equal to, this kind 9 of exposure to something else.
10' And the man would more or less associate the thought j
.11 with rems.. I think- this is the avenue that I would like. to-4 12 see explored, but reat in the avenue of trying to compare 13 as comparing, it I am putting it correctly. '
i 14 MR. ROECKLEIN: I think I understand.'
15 VOICE: Just one question. No. I says what is meant ,
16 by risk. Was it your intention to define the word " risk"? !
17 MR. ROECKLEIN: No. -
18 VOICE: It was not?
19 MR. ROECKLEIN: Let me repeat my intention.
20 At this point we are addressing the questions to ask. ;
i 21 We haven't really gotten to the answers at this point.
22 MR. ALEXANDER: The main concept we want to deal with '
23 is that a lot of guys want to say yes or no. Will I get cancer :
24' if I work here, yes or no? Am I going to die of cancer if I 25 mrk here? We- have got to introduce a concept E=me that's like saying,
= _ . _ _= _ ...___.
ACE .eFDERAL REPORTERS, INC. (202)347-3700
$16.07.10 69 ;
emw I ' will the piste land at 5:00 o' clock or at two minutes af ter 2 5:007 Nobody knows. There is a probability that it will 3 land at 5:00 o' clock. That is wh,en it's due. 90 percent of 4 the time it does, but 10 percent of the' time it lands at 5 two after.
6 So there is a risk it's going to be two minutes late.
7 We can't tell you if you'r. 3;in; to get five rems S you're going to die of cancer or not.
9 VOICE: So at' this point we are not talking about 10 comparative risks, we are talking about the concept of risk.
.11 MR. ALEXANDER: The concept of risk.
12 VOICE: All right.
13 ' MR. ALEXANDER: These guys can pick up on that, 14 because they know how to play poker. You just have to lay gj e) 15 it out for them in those kind of words.
16 l
17 18 19 20 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC. (202)347-3700
$16.08.1 70 bw I MR. SH.00P: Is there any industrial data available 2 on the f acilities? I am sure there is. Most of the states 3 report to us. This is really what the worker. can compare, 4 If he's going into radiation work or, say, he wants to go 5 into.the buildlng trades as a wireman, if he's one of our 6 members..
7 MR. ALEXANDER: What kind of data are you talking 8 about, Paul?
9 MR. SH.00Ps How can he relate to what's happened 10 in some other industry, what are the f acilities? What are
.11 the se rlous injuries?
12 MR. ALEXANDER: We have got a little bit of data.
13 We have got good data on accidents. You can talk about 14 100,000 people working so many years, how many of them are 15 going to have an accident.
16 MR . S H.00P 2 The guy understands this. He's 17 pre tty smart. Maybe he is not interested in -- maybe he is.
1S I don't.know, a lightning bolt coming out of the blue on the 19 golf course. He has his club up and it zaps him.
20 MR. ALEXANDER: Well, there's pretty g. cod data -
21 on that sort of thing.
22 MR . S H.00P I think we have to keep away from the 23 theoretical stuff .where no one knows. Stick to what we do 24 know, on average. _Because we are deellng with large numbers 25 of people involved in these things, and we can be fairly ACE-FEDERAL REPORTERS, INC. (202)347-3700
l 16.08.2 71 bw I accurate. We' can say how many are going t.o get snaked on 2 and die. We can work with mortality tables. We know how 3 many are golng to die and this kind of. thing. If you don't 4 want the general population, get down to the industrial 5 population, where again records for.this study exist. Keep 6 it where the guy can understand it. Keep dt practical. He 7 is pre tty smart. He is not all that low-level intelligence.
8 You are not going to get him involved in reactor physics, but 9 he is a poker player, like you said.
10 He knows the odds.
.11 MR. ALEXANDER: I think we need to give him the 12 o dd s.
13 VOICE: That's it, that's what we have been asking 14 for.
15 MR . ALEX ANDER : So f ar the odds are not that bad.
16 One of the conclusions that we came to in our analysis of the 17 dose limits question is that if we lower the dose limits so 18 far that the nuclear power industry is knocked out, and we ge 19 to some other form of plant, chances are the worker will go to 20 work in an industry that is more dangerous.
21 MR. JOY That is what we have been getting down to.
22 There is no such thing as a ' risk-f ree industry. What the 23 people are saying about cancer is that they want to eliminate 24 all the risk of cancer. All we are saying is, let them know 25 what the risk is. Everything you say is coming down to that. -
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-6.08.3 72 bw 1 Risk versus the other industry. There is no other way of 2 comparing it.
3 MR. ALEXANDER: The way you are coming across to 4 me today, I don't know about Alan, is that.your members 5- don't really have a whole lot of diff erent questions.
6 MR. JOY: N o '.
7 MR. ALEXANDER: They have got three or four they 8 want answers to.
9 MR. JOY: You bet your life. It comes down to what 10 is the risk of getting cancer,. period. They have got a lot
.11 of stuff. that is stf11 In their head about the future effects 12 of radiation. If you can't kill it now, the industry, kill it 13 .later. You have the unknown f actor, what is going to happen 14 30, 40, 50 ago, what is going to happen to your 15 genes or what is going to happen to your o;ff spring. This is 16 the fear being permeated into the people. Every guy that 17 goes into a nuclear installation someday will feel, if I am IS not at child-producing age, something ls going to happen to 19 my offspring. What we are saying is lay out the adds. Show 20 them what it really is. l 1
21 MR. ALEXANDER: How about the genetic ef.fects? l 22 Your Nuclear Saf ety Committee had quite a bit to say to me 23 about genetic effects. I picked up a good deal of concern I l
24 there that surprised me a little bit. )
1 25 MR. JOY: Yes. I have talked to a lot of people
)
ACE-FEDERAL. REPORTERS, INC.-(202)347-3700 9 w
--M mV T y- y -*ey- mwf ema-r -++fu.P-g, .g *+<&-- _ va 8 m v - - -
$ 16 .08.4 - 73 bw I around the locals and you are starting to pick this up. We .
1 2 are ge tting sort of a . national debate here, whether or not l l
3 we are going to have nuclear power. If you are going to i 4 affect the worker to where it is a fear tactic you are not 5 going to have nuclear, because nobody's going to work in a 6 plant.
7 This Is where the responsibility has to come.- We 8 say if the plant is saf e, fine, tell us it is safe. If it 9 is not, shut the go.ddamn thing down. That is where we are 10 at.
.11 VOICE: Take a look at question 19 that you have.
12 That is a very good question. I want to t e ll yo u why . One 13 of the workers we represent, one of the companies has 14 limits that they.tell the workers at indoctrination are 15 lower than the NRC limits. Then along comes the agency, and 16 they push them beyond those limits, but still within our 17 l imit s .
IS Now, the worker says, "Well when was the 19 company telling the truth? When they said I should stay at 20 this low-level or now, because they are desperate, they are 21 pushlng me up higher?" So that backfired. It caused a great 22 deal of fear and mistrust. That is why we asked you to set 23 out your standards and get in on the indoctrination. In the 24 transient worker, that change from the lower limit to still 25 the acceptable higher limit caused mistrust of the company.
ACE-FEDERAL REPORTERS, INC. (202)347-3700
bl6.08.5 74 bw I One of the major problems.
2- MR. ROECKLEIN: I remember that as a difficulty.
3 VOICE 2 I don't know how you are going to answer 4 the question. -
5 MR. ROECKLEIN: I think the administrative 6 limit gives you a saf ety margin for the licensee to avoid 7 exceeding the NRC limits which involves reporting and 8 potential fines and other things.
9 MR. JOY: There seems to be another thing when 10 you get to ALARA. And the misconcept of ALARA. The JI safest way to work, the least amount of low-level exposure.
12 Everybody understands what the philosophy is, but the 13 individual thinks that ALARA means they shall get a lower
~
14 dose.. So what happens is they do it in a safer manner, 15 bring it down as low as achievable, but then the same 16 individual still takes his full five for the year. The 17 same individual, regardless of how safe he works and how 18 expedient he works, it is not spread around. He f eels he 19 shouldn't have to take the five. That that should be spread l l
20 around. He never sees ALARA. The individual who is in 1 21 there never sees ALARA, because it is usual he's going to take l
22 the f ull dose amount. '
23 MR. ROECKLEIN: Are you seeing a lot of your people 24 up at the limits ? l 1
25 MR. JOY: You are damn right we are, es pe ci ally l l
l ACE-FEDERAL REPORTERS, INC. (202)347-3700
46.08.6- 75 bw I. on-a major outage. The maintenance'part of the 2 Installations ~ right now are at their maximum rate, most of 3 'them. If they had anything go wrong,.they would have to 4 bring people in. They don't see ALARA. Sure, the company 5 is trying to do the best they can, they are trying to get 6 the job done with the least exposure, but the same people are 7 being exposed to the full amount.
8 VOICE: As a ma.tter of f act, at one of the ses sions, 9 I don't know if it was you, .you gave - us an a ferage exposure 10 rate to people working at nuclear plants. We were
.11 startled by it.
12 MR. ALEXANDER: That was the first meeting, I 13 told you that our records show it is .7 rem per year. You 14 didn't believe it. .
15 VOICE: We still don't.
16 VOICE We don't belie ve it.
17 MR. ROECKLEIN: Le ss than I percent last year 18 exc eeded four rem.
19 VOICE: That is not our experience, not at all.
20 MR. ROECKLEIN2 You have got the 1 percent.
21 VOICE: You have to answer as these plants get 22 older, and as it becomes more intricate, that the exposure 23 levels are going to be greater to a greater number of people.
24 When Indian Point went on in 1956, that was taken down as an 25 experimental plant, but the workers are going to have higher ACE-FEDERAL REPORTERS, INC, (202)347-3700
46.08.7l -
76
.bw I level's.as the plant gets older. Anybody who' argues that 2 ls a fool, because it has to happen.
3- MR . S HDOP : . The approach IBW has taken with ALARA, 4' and I think we have P3en fairly successful, is that we make 5 this inf ormation known to the member, at the various power 6 - reactors. Deing a bargaining unit, ther than an open shop.
7 they do ha v e some clout. Yes, the individual.might get the 8 5-rem or maximum of 12 in a year, but on average, by taking 9 an active part, knowing what ALARA is and the concept, 10 by saying, "Look, Management , we have to do something
.11 differently here." I think they are very ef f ective , but 12 you have to get the bargaining people involved in it. This 13 Reg GWWh. isn't addre ssed to that, but I think this is part 14 of the problem in making ALARA successful. Get the ,
15 individual worker, and where he's represented by a union, he 16 .can'be very eff.ective in bringing abou't change.
17 MR. ROECKLEIN: That is a function of training. l 18 MR . SH.00P Well, not nece ssarily this group. But 19 it can be very e ffective.
20 MR. ALEXANDER 2 In my talking with workers, Paul, 1
21 I get an impression, pretty strong, Jim was just talking 22 about it, when you say ALARA to a guy, 'he's thinking about 23 one thing, his dose.
24 MR. JOY: Right.
25 MR. ALEXANDER: One of the things we want to try to l
I E
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1 1
il6.08.8 .77 1
1 bw 1. get acro.ss, maybe it is a mistak'e. See what I think, is !
2 that there is another way to look at - ALARA. That is from 1
3 the ' collective. From the overall -- i 4 MR. JOY This is exactly what. is missed with the !
5 worker.
6 MR. ALEXANDER: What's missed.
7 MR. JOY Right.
8 MR. ALEXANDER: Do you think we can try to answer 9 that question here?
10 MR. JOY: You.can try to answer it, but again he
.11 f eels he himself should be involved personally. That it 12 shouldn't be the collective.
13 I understand the collective very.well. The more 14 people exposed, the more problems you have. The,less people 15 exposed, the better it is. I' understand that. But he-16 f eels he's ge.tting the short end of this. As far as 17 negotiation, we are talking about available people working 18 in a plant. The question comes up, if the job can't be 19 done with those people, they are going to be moved out of 20 the plant, period.
21 We are talking about jobs, livelihood, what have 22 you. But ALARA doesn't s.eem to get into those people, not 23 saying every one of those guys take the full dose, but they 24 f eel regardless of how saf e or expedient they were, their 25 dosage is not going to be reduced. Them, personally.
ACE-FEDERAL REPORTERS, INC. (202)347-3700
1 j
$16.08.9 78 bw 1 Collectively, yes.
2 MR. SHOop: The approach we have taken, Bob , -is ;
1 3- that on the total man-rem, and this is the effects of I
4 ALARA -- '
5 MR. JOY: We are not telling a mechanic that.
6 MR. SHOOP: We are telling the mechanics that, 7' because these are our members. The concept is on an 8 average. . It is not the individual. The individual may 9 benefit under ALARA. Hopefully, the individual is in a 10 situation, if he says, " Gee, you know, right here I have
.11 got 10 millirem per hourt back here I have got 5."
12 Hopef ully, the individual is smart enough he's, back here 1.3 where he's getting 5. But really when we are talking about 14 the concept o'f ALARA, we are talking on_an average for that 15 site for the whole industry.as such. These are the things 16 we have gotten across to your members. This is what they 17 are looking for. How do we reduce the total man-rem per 18 year per unit?
19 MR. ROECKLEIN: So you are both saying that is 20 an appropriate topic for this guide. Apparently.
21 MR. SHOOP: I think ALARA is a concept, because 22 ALARA fits in with the risk, .as low as reasonably 23 achie vabl e , then we are getting into a philosophical approach 24 to it.
25 MR. ROECKLEIN: Okay.
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'bw I VOICE
- There is no argument to the concept of 2 ALARA.. As low as we can make the risk, everybody must j 3 agree with that. The po int is where we have permanent !
l 4 base house gang, permanent mechanics, I'am not talking 5 about transient workers'now, under the allowable limit 6 before ALARA was conceived, and we had higher radiation l
~
7 jobs, they could only do so many jobs, then they were 8 moved to a noncontaminated area, so to speak. Maybe they 9 got their limit in six months. Now they were taken out 10 of the nuclear area.
.11 With ALARA, they can work nine months in the 12 contaminated area. At the end of that period they have 13 still got their full allowable limit. Or they can work a 14 year. But ,they have still got thelr full allowable limit.
d)9 15 You can get more work done with the people or with the 16 addition of transients, but the average man still got his
. 17 maximum dose and was not cenefited by the ALARA concept.
18 MR. ALEXANDER: That is an interesting point.
19 20 2!
22 23 24 25 l
ACE-FEDERAL REPORTERS, INC. (202)347-3700
I f 6. 0.9.1 80 rc 1 MR. JOY We understand the philosophy of ALARA very 2 well. We are telling you what the problem with the worker is.
3 We agree with the philosophy of ALARA but the worker says. I 4 am there. I am not benefited. What the hell good is ALARA to 5 me? I am still getting the cumulative effect.
6 VOICES. Even if you come up with these standards, you 7 have to be able to substantiate them .because one of the big S problems with the, wlth getting five rems a year, this can be 9 acceptable perhaps to a person and was generalJy in our locale 10 there, until you got some of these -reports that came out.
.11 No matter what you set up as safe or reasonable, if 12 someone comes out with a report that says it should be 13 one-tenth of this, then we believe the Commission should be in i
' 14 the position to come out with some stateme.nt to substantiate l I
15 the reasons that they arrived at these particular limits.
l 16 It doesn't help at all to set them and explain why i 17 you did it and then have someone who is equa.11y recognized in l 4 1 IS this fleid to come out with some of the reports that we have 19 seen recently. That is where most of the trouble started in 20 .our own plants.
21 MR. ROECKLEIN: So , you are re f e rring, in a sense, to 22 some of the questions on this list, 20, 21, 22.
23 VOICE 2 Yes.
24 MR. ROECKLEIN: You feel this guide should include
- 25 some statement by the NRC?
ACE-FEDERAL REPORTERS, INC. (202)347-3700 j
81 fl6.09.2 rc 1 VOICE: Yes. And I think the Commisslon, in the long 2 run, has to be able to come out with statements, answers, 3 rebuttals or an agreement with these reports are made. That is 4 the only way we will be well-informed on it.
5 MR. ALEXANDER: I.think one of the points we can mEke 6 in answering this question about collective dose, one of the 7 points that I want to make, and I don't see any reason why we 8 shouldn't do it here, and that is that the only way to reduce 9 the overall risk from radiation is to reduce either the dose 10 rates or the working times or both. Anything else you do is
.11 only going to spread it around to other people and you won't 12 have accomplished a thing. I think we can make that point.
13 VOICE: Maybe another question that should have been 14 on that list, because of what had been said here, is, say, a 15 guy does get five rems every year or four or five years. Is 16 his risk any greater than a guy that only gets 3.57 17 MR. ALEXANDER 2 That point will be made in one of the 18 answers to the earlier questions about biological exposure, where 19 we will. point out that the more dose you get in your lifetime, 20 the greater chance you have of getting radiation induced 21 cancer.
22 VOICE 2 And the relationship.
23 MR. ALEXANDER: Yes.
24 VOICE: Yes.
25 MR. ALEXANDER We have a little film strip to show ACE-FEDERAL REPORTERS, INC. (202)347-3700
~_ -
bl6.09.3 82 rc I you. that can give you an idea of one approach that has been _
2 taken. I don't know whether all of you have seen this strip or 3 not. ,
4 VOICE: Can I ask a question o.ff the subject f or a 5 moment.before you go to that? It will just take a minute.
6 MR. ALEXANDER: Sure.
7 VOICE: With this standard for protection against 8 radiation, are those going to be published, that standard?
9 MR. ALEXANDER Yes, everything we have got is open 10 to the public.
11 VOICE Most of the standards and regulations. it 12 says someplace in It whether it is going to be a public record l.3 or not. ' Dais one doesn't. That Is why I raised .the question.
14 MR. ALEXANDER: It will be.
15 VOICE: Because those are going to be individual 16 doses now instead of the accumulated summary that they had 17 before, right?
18 MR. ALEXANDER: Wait a minute, Marshall. Are you 19 talking about the new reporting requirements?
20 VOICE: Right.
21 MR. ALEXANDER: They will be handled the same way --
22 the re is nothing new as f ar as your members are concerned.
23 That will be handled the same way it's always been.
24 VOICE: Except that they will be broken down by 25 individuals _ now, right, rather than a summary?
ACE-FEDERAL REPORTERS, INC. (202)347-3700 ,
ii6.09.4' 83 rc 1 MR. ALEXANDER No.
2 VOICE 2 That is what I read here.
3 MR. ALEXANDER No. We, are' going to require of all l
4 'of the other licensees the same statistical information that 1 1
5 reactors have to provide now. !
6 VOICE 2 Then all that is going to -- l
_ 7 MR. ALEXANDER: The only individual dose data we get l 8 are from the termination reports.
9- VOICE: Then the only thing in the reports is it will 10 say that these four people who had 5 rems, 8 people who had l i
.11 1.77 !
12 MR. ALEXANDER: Yes, except for the termination 13 reports.
14 Is Walt gone ? Yes.
15 I don't.think we required.the -- I am sure we didn't 16 require the termination reports of the other licensees. So, 17 all we will be ge.tting from all those other licensees is the 18 sta tistical information. We won't have anything by name of the 19 worker.
20 We do have the termination reports by name o.f the 21 worker from the power plants. That is because of that 22 transient worker problem. We run the computer once in awhile 23 to see if anybody is getting more than three rems in a quarter 24' by golog f. rom one plant to the other. !
25 VOICE: Isn't part of this information here? I read i
i i
ACE-FEDERAL REPORTERS, INC. (202)347-3700
'6.09.5 84 rc 1 a week or so ago. But I thought some of it is now that part of 2 the' records which they kept to prepare their summary which they 3 sent in, they have to send in the, backup. records with it.
4 Maybe I am reading it wrong, b'ut that is how I 5 understood it.
6 MR. ALEXANDER No. We require them to keep that P
7 Information so that we have access to it anytime we want it.
8 But we don't regulre them to send it in.
9 VOICE: See, I was hoping to get to the problem Paul 10 talked about.before. And that is ge.tting informatica relative
.11 to an individual and his .cumulation record. I thought this was !
12 going to eliminate some ~ of that problem, but I guess it 13 doesn't.
14 MR. ALEXANDER: I don't think it wi.11.
15 VOICE: Okay. We will have a comment or two then.
16 MR. ROECKLEIN: That is another i.ssue.
17 Well, let me put this fihn redp into context. One of.
18 the possible ways of presenting this instruction on this would 19 be some sort of audio-visual thing, either as the appendix to 20 the Guide or as a supplement.
21 We borrowed a segment of tape produced by the 22 Industrial. Training Corporation in Rockville on the 8.13. They 23 did a three-segment video tape which presents the instructions 24 by Reg Guide 8.13. . This is just the third segment.
25 Our reason for having it here is to give you an ACE-FEDERAL REPORTERS, INC. (202)347-3700 m e w g--,-o - -
16.09.6 ~ 85 rc 1 example of what one presentation might be related to the topic 2- we are talking about'today. It is only about six minutes long.
3 Then maybe we can get back to what you f eel ls the best 4 approach to..this.
5 (Fllm shown.)
6 MR. ROECKLEIN: The. only reason we had this here was 7 to give you an idea of what could be one alternative approach 8 to this Reg Gulde, a video tape or audio-visual presentation of some kind. We are still back to looking at the four 10 possibilities. It sounded to me like you seemed to like the JI question and answer approach to the development of the Guidei 12 is that correct? -
13 MR. JOY That is correct. The video is terrific.
14 It is gre'at.
15 MR. ROECKLEIN: Pardon me?
16 MR. JOY This is terrific. This kind of business.
17 of course, the question and answer certainly comes af ter that, 18 but the video tape, going into detail with workers before they 19 go in, perhaps developed by the NRC would be a tremendous 20 thing, I really think so.
21 MR. ROECKLEIN You see it perhaps as a supplement?
22 MR. JOY: Absolutely.
23 MR. ROECKLEIN You are going to comment?
24 MS. MAC DONALD: I just said that is an excellent 25 supplement. That, plus the written. It ,gives them time to ACE-FEDERAL REPORTERS, INC. (202)347-3700
- - - . . ~ - . -
$16.09.7 '
86 rc 1 think1 and talk.
2 MR. ALEXANDER
. What do. you think about whether. the 3 government.should do tapes like that or not?
4 MR. SHn0P2 No. '
5 MR. ALEXANDER: That was done by private Industry.
6 MR. JOYS Regardless of who does it, as long as it 7 comes out that way.
8 Let me ask you something acout -- why can't a private 9 ind.ustry have a training program on a Reg Guide, why can't ycu 4 10 approve or disapprove it?
.11 MR. ALEXANDER 2 We only have authority to regulate ,
12 our own licensees. That's not quite true.- If you try to walk .
4
.around with 'some radioactive material and you don't have a 13 14- license, we can do something about it.
15 VoJCE: If there was a definite Anaccuracy in a ,
16 training film, I would think that your power covers that. You 17 could certify to the truthf ulness of the film, of the training 18 fllm. Isn't that within your jurisdiction? Did you govern 19 the training of the radiatlon workers? t 20 MR. ALEXANDER I don't know. You are getting into 21 legal questions now. I know we would have'a problem endorsing 22 a film by one company when there are other companies making 23' competing films.
24 VOICE: I didn't mean endorse, but certify that they-25 are correct. ,
ACE-FEDERAL REPORTERS,'INC. (202)347-3700 ,
16.09.8' '87 re 1 MR. ALEXANDER: We could do that.
2 VOICE We do have a course in training . for 3 industr.ial radiography. That is done by the Office of Nuclear 4 Materials, Safeguards. -
5 MR.! ALEXANDER Those are license conditions, though, 6 aren't they?
7 VOICE: No. They will put a stamp of . approval on 8 different courses. For example,' LSU has a courseLwhich is 9' considered by NRC as acceptable training to meet certain 10 minimum require.ments in Industrial radiography.
.I l I.n addition, the individual licans.ee has to provide 12 training which-1s specific to the equipment that he's using, 13 specific to that. But we do approve and we keep -- there is a 14 catalogue, a very small catalogue certifying various courses 15 given by private industry as acceptable for meeting certain 16 training' requirements.
17 MR. ALEXANDER: While we are on this subject, I want j
18 to show you another tape. .This one paid for by Uncle Sam.
19 Now, this one is on respirators.
20 Let's do the second one on atmosphere supply -- you 21 paid your share of this one. It runs about 20 minutes, or
- 22 less. It was done at Los Alamos Scientific Laboratory. The 23 .way it will be used, it is being modified right now to stop.
24 You noticed the.way that b d stopped, she said you probably-25 have questions, stop the tape now and answer questions. This ACE-FEDERAL REPORTERS, INC. (202)347-3700
__~ ,_ . _ _ . - - - . , _ . . _ _ . . . . _ . . - . . . _ _ __- _ _ _ . . ._ .
16.09.9 28 rc I one 'is' being modified that way, so it can be stopped by the 2 instructor to answer questions by the class.
3 The reason I have asked Je.rry Caplin to show this-4 tape is I want to, on this one, specifically request your 5 written reection. I want to know what the unions think about 6 .this tape. That .is not much to ask. Just write a letter and 7 say it is no damn good, or you think it as great. That is all 8 I want to know.
~
9 MS. MAC DONALDs After we see this tape, wLl1 you 10 explain to us why you are reluctant to get into making tapes?
.t l MR. ALEXANDER: Wait a minute, I have got two 12 comments. What did you say?
13 MS. MAC DONALD: After we s.ee this tape, wi.11 you 14 explaia to us why you are reluctant to get into making tapes 15 as an accompaniment to --
16 MR. ALEXANDER: At the time we made this one, nobody 17 in the open market had appeared with any. Now you see we have 18 a company or two making them. We are beginning to worry about 19 competing with them.
20 MS. MAC DONALD: I see.
21 MR. CAPLIN: Let me explain a couple points about 22 this tape. Originally, the thought was, as Bob sa.id, no o ne 23 was doing. this sort of. thing at all. We f elt there was a need 24 for additional information -- by the way, there was a mistake 25 on the.last one. The girl that had the respirator on was s
ACE-FEDERAL REPORTERS, INC. (202)347-3700
1 16.09.10 89 l
re- l' . wearing It wrong.
2 MR. JOY: That shows why private industry possibly 3 shouldn't be making them. That's, g ood.
4 MR. CAPLINJ I think they can*make them and make them l l
5 .okay, but somebody should review what is shown. The thought, I l
6 at first, was to have a Regulatory Guide. Maybe-I should go '
7- back and say what we do about respiratory first_ qu.ickly. .and 8 explaln where these sit with that.
9 MR. ALEXANDER 2 We don't have much time because they.
10 have to leave at 1:30.
.11 MR. CAPLIN2 Okay. I will shorten it up then. ,
l 12 As part of the regulatory program, we thought we ;
13 would include additional Regulatory Guides to the one we
'4 already have on respiratory protection that would be specific 15 to individual subjects, break it up into smaller pieces, 16 because not everybody can absorb everything if you are going to 17 present a six-hour seision, nobody will remember anything.
18 But you can break the subject up into 15 or 17 or 19 20-minute segments and somebody carries something away with 20 that.
21 So, the idea, at first, was to make these -- have a 22 Regulatory Guide and have a video tape supplement to that 23 guide. So, at the introduction to this, you will say this is 24 a supplement to the Regulatory Guide, and so on.
25 Now, that ldea had been abandoned. We felt we could ACE-FEDERAL REPORTERS, INC. (202)347-3700
1 116.09.11 90 rc 1 get it out f aster in a be.tter way, more as a trainlng format.
2 The original ideo 14 as something for the licensee, but we are 3 going to put it into more of a tr,aining gulde format. It will 4 be put out and available, but the though't is that it will have 5 a stop-tape technique similar to the one you just saw.
6 And we wl.11 put -- have a supplementary booklet that 7 will go with it that won't be necessarily a formal Regulatory 8 Guide, but something that a worker could take, go into a room 9 where one of these was available, put it on, and Icok at the 10 tape, stop the tape himself or with an instructor there. The
.11 book could be used either with or without an instructor. We 12 would like somebody to be able to use the book himself.
13 The booklet would try to put into simpler terms and 14 give further explanation of what you see in the tape. So, the 15 tape would be used as in a similar way to the one you just saw.
16 So what you are going to see was the way it was originally 17 made. And we are going to modify it. We are in the process of 18 modifylng them now. They won't come out as the guldes, 19 although that is what it will say on here.
20 I just wanted to warn you about the difference so 21 everybody is clear on what we are doing.
22 Now, this is on acceptable practices .for the use of 23 atmosphere supplying respirators. Remember, it won't come out 24 in the form you are going to see it. It will be a stop-tape 25 technique and a supplementary booklet for the individual. worker ACE-FEDERAL REPORTERS, INC. (202)347-3700
116.09.12 91 rc I would be available.
2 (Film shown.)
3 4
5 6 -
7 8
9 10 Ji 12 ,
13 14 q 15 16 17 18 19 20 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC. (202)347-3700 3
92 I
'eri 1 1 MR. ALEXANDER: Okay, let's hear it. !
1 1516 caig 10 2 VOICE: Well, it's an excellent technical manual. l 3 But it doesn't address itself to 'te problems we hear the most i i I 4 from the men who use it. I think' you go.t a little of that when '
1 5 you talked to our committee. It doesn't address itself to the 6 necessity for communication between two workers working on the 7 same job, it doesn't address itself to fogging, it doesn't 8 tell;the proper way to put a mask on or the proper way to take 9 it off, especially if the outside is contaminated.
I 10 The simple things the retraining program ignores.
Joh 11 hand him a mask. You assume he knows how to put it on and take 12 it off. When it takes it off, he gets a dose. This is what 13 we see in the field. Two. mechanics working side by side in the 14 field. When they have to tell each other something they pull the I
15 mask off and tell something. Then they put the mask back on.
16 That is how they get the dosage.
I 17 We need a manual to instruct the worker on the j i
18 proper use of the equipment.
l 19 MR. CAPLIN: Okay, two things on that. One is, 20 remember, as I said, this originally was made to -- not so much 21 !
as a training item as to address the licensee as to what he was !
22 to do. We are going to convert it into a kind of a training 23 item. Also this was one of the introductory things we had out l l
24 of a whole series, some of which, further ones, will deal with '
>Feerd Agomers, lnc. i 25 the kinds of things you are talking about. This one and the onei l
. . 93 jeri 2 1 before it were tapcd simply to mainly show the kinds of equipment 2 that there are, that the worker will b.e encountering, so that 3 the person who sees the rest of the tapes will be f amiliar with 4 what it is you are talking about.
5 You are talking about an air purifying respirator, 6 or you are talking about a pressure demand supplied air 7 respirator. So he will have some familiarity with what you are 8
talking about. That was what this -- the point of that tape l 9 was.
10 In other tapes, I agree. You would have to have -- l 11 also, remember, with this one, there will be a booklet with 12 further explanatory information in it which would be aimed more 13 at direct training. And any other tapes we would make would i I
l 14 cover these things, such as how you wear the thing and how you l 15 are supposed to put it on and the f act that you don' t take, it 16 off and talk in a contaminated atmosphere and so forth. How 1
17 it ought to be fitted. The three we have made that we are 18 modifying are, one on air purifying respirators, this one on j I
19 atmosphere supplying respirators. And we have one on methods of' 20 respirator fitting. That one just discusses the different i
21 methods there are to fit a respirator to a person.
22 There are a lot of things going on in respiratory l l
3 23 protection that need fixing. Training is one of them. I 24 MS. MAC DONALD: My question had been who that was sJeoeral Reporters, Inc.
25 intended for. You said the licensee?
I
, . 94 JERI I 1 MR. CAPLIN: Originally, yes. Go ahead.
2 MS. MAC. DONALD: I still think that the problems that he brought up are important for the licensee to understand too. ;
3l t i 4 When you have got to communicate, when you have to take a break 5 just to get that thing off your head. If it could be a film 6 that was not so complicated, I mean really moved right along.
7 If safety committees could understand it equally'as well as 8
the licensee, then everybody would be on tte same page in terms 9 of understanding use and operation and maintenance and so forth.
10 MR. CAPLIN: That is why we want to go to a 2 . , l 11 stop-tape technique, so that the tape would be stopped and the 12 person would read further explanatory information. Because it 13 is not originally intended to be just a training tape. It was 14 originally intended for a different format. And we are convert-j 15 ing it to the other way. ,
16 If we made other tapes, if we decided to do that, i
17 I think they would be aimed more directly toward a training f f
18 format to begin with and you wouldn't have some of the problems l l
19 that you are bringing up.
20 MS MAC DONALD: But the technical information is 21 useful for both sides to have.
22 MR. CAPLIN: Yes, there is no reason why the licensee 23 couldn't also use it. It's just the point of focus ' that we are t
l 24 talking about here.
a Feed Rummn, Inc. l 25 MR. SHOOP: One of the problems our members have had l ,
t
95 jcri 4 1 is acccptanca of some of those devices. Soms are not as 1
1 2 .p opular as others. I haven't used all of them myself so I don't know but I would guess that are some valid comolaints l 3 .
!I 4 there . Economics is one, I am sure. Some devices are cheaper l 5 than others. ;
1 6 MR. CAPLIN: Yes, you can get non-approved devices l
7 that don't cost much and don't do much. At Los Alamos, as far 8
as the -- if you are talking about the point of view of the 9 purchaser of the device, that is one thing. If you are talking 10 from the point of view of the person who ha's to wear it and how 11 much he's being protected and how acceptable it is to him, that 12 is a very important aspect of training people in the use of 13 respiratory protection.
14 We have a great deal of data from Los Alamos._Among i
1.s the things that they look at when they are testing all the 16 respirators for us on panels of people, panels of size faces, 17 they get information about things like comfort, ability to see. l 18 The visual field. Whether or not the thing is too noisy. They ;
I i
19 deliberately look for that information, they ask the people 20 about those things. We have a great deal of information about 21 it. l 22 It is true , there are some devices that are approved i
23 the same as another one is approved, but one the majority of l
i 24 people will find more confortable.
co Fooer:q f.eporters, Inc.
?? 25 , MR. SHOOP: The Kemox is one we have had more 1
l i i
i e
(
9s 3ri 5 )
complainto on.
2 MR. CAPLIN: I think the Kemox is going to be 3
replaced by other kinds of devices in the not too distant future..
I ,
4 The approval for that I think is going to be rescinded.
l 5
MR. ALEXANDER: Wou have seen the sort of thing we 6
have for you. What we would like to know from you, and I will 7
need it in writing, what you think we need, or pardon me, what 8
y u think is needed in the way of videotape supplements.
9 Perhaps your answer is, nothing, we don' t need them. Or if we i
10 need them, we will make them ourselves. Or let private industry' 11 do it. But if you think we ought to do it, and you think we 12 ught to do it'a certain way, then let me know, because we have 13 some decisions to make which involve funding. One of the y reasons I just, while I had you captured here in the room, I i
15 th,ought I would show you this tape and try to get a reaction 16 out of you about this problem. Thank you very much, Jerry.
77 VOICE: I would like to address one thing on this . ;
18 MR. CAPLIN: Yes.
I 19 VOICE: I don't know whether it should be addressed i 20 in these questions or here. The respirators. Now there are 21 times, I will use the word " cop-out" again, it is the easiest 22 way ut for the company rather than ventilate the contaminated f
'3 area, which they can do, they have air locks and what not. So l I
i i
24 they would rather go to the respirator than to ventilate.
- ..rmni nnenen, ine. i 25 MR. CAPLIN: What they would rather do according to ; '
I L___ ___
97 jeri 6 ; our regulation is not relevant. Our regulation ac now writttn i
2 and went into effect fully, I guess last December, maybe, we 3 changed it, it requires that the licensee not use respirators !
4 as a first line of defense and that practicable engineering {
5 controls be used where they can be used. We do not regard 6 respirators, we never regarded respirators as a primary means 7 of protecting people in the industrial environment that we 8 control.
9 VOICE: Well, they use that at the outage.
I 10 MR. CAPLIN: Sometimes you have to use them.
11 VOICE: The outage was before you changed the regulad 12 tion, am I right?
13 VOICE: I think we might be talking about two differ-14 ent things. I think on a planned outage you might get as much ,
15 venting as possible. It is an unexpected f allout where the 16 downtime of the company, they are anxious to get that unit back i
17 rather quickly. Sure, they could vent. That is going to 18 increase the downtime of that unit. When you get into that kind ,
19 of discussion, they will use respirators. I Em going to assure '
20 you that they won't keep that unit down one minute more than they l
21 will have to, especially the big ones. j i
22 I don't mean radioactive fallout, I mean when the 23 unit falls out, an unexpected outage. They won ' t go to the ;
24 venting if they can use respirators.
>rious moomn. inc. .
25 MR. CAPLIN: They are supposed to use as a primary i
98
- ri 7 1 maana of control. This is for ordinary operations. If you are 2 talking about an emergency situation, there is all kinds of I
(
3 degrees of shading. i 4 MR. JOY: Evidently it'is an emergency. l 5 MR. CAPLIN: -- times when it would be appropriate 6 and when it wouldn't to start using the respirators. I would 7 think that would be a labor-management kind of thing. But as I
8 far as in the first instance, for usual, normal operations, I I
9 you don't expect to have people running around wearing 10 ! respirators for that kind of thing. You expect to design 11 those problems out to begin with. Yes, you have got big 12 reactors, you are going to have outages, downtimes, all sorts 13 of situation's where while you .are either instituting the other 14 controls or to take care of the situation as it exists, the 15 only thing you can do to protect people, or the best thing you ,
i 16 can do to protect them or keep their exposure as low as achiev ;
17 able is to give them some additional respiratory protection.
I 18 But then we want to make sure they are doing it the :
I 19 right way and using the kind of thing that is really going to do 20 the job. A respiratory protection program is a major kind of l i
21 undertaking. Just buying the thing and slapping it on a person l 22 is simply unacceptable.
l l
23 VOICE: On this , I am aware that there is a policy l 24 that okay, for outages and the like, obviously you are going wre-a anenm. inc ;
25 to do it. For routine use of respirators, which does occur in l
6
l . ,
gg I
jeri 8 j the industry ---
2 MR. CAPLIN: It should not. Routine use, in routine 3 situations, the usual routine situation, that is, one that you I
4 are handling every day, I am not talking about an outage, an l
5 outage can be considered a routine thing in a sense, too.
6 VOICE: I am not talking about an outage once --
7 MR. CAPLIN: I am talking about everyday kind of 8
situations. To the extent it is practicable to engineer them 9 out, then they ought to be engineered out and you ought to have i
10 ventilation controls for routine situations. It is for the 11 non-routine situation or the emergency situation or the 12 infrequently occurring operation that you might consider using g3 respirators and that would be if I had an acceptable substi-14 tute.
15 MR. ALEXANDER: You are absolutely right but 16 everybody in the room knows there are situations where' licensees 17 routinely use respirators. In the yellow cake area they don't l 1
18 provide ventilation, they just put on respirators.
19 Frank is fixing to ask a question about that.
20 VOICE: I am just wondering what enforcement powers 21 you have on licensees. For instance, fuel rod fabrication plants' l
22 I know one where it is routinely used. They don't seem to be 23 wanting to change, either. ;
,l 24 MR. CAPLIN: There are two usages you can consider I a-Funo v.wonm, Inc.
routine. Somebody might have a person uearing or carrying a ll ij 25 il
!l 1
100
- L 9 1 respirator as a precautionary proccdure whero no credit really 2 had to be taken for it in that sense. The other sense is where 3 you really have a hazardous area and you are sending the person i
4 in all the time and he has to wear the thing in order to get 5 by at all. Those are the twa different kinds of situations.
6 MR. ALEXANDER: I think the answer to your question 7 is that the licensee has to convince our inspe.d.or that it would g be impractical. Well, I guess he really has to convince him 9 of either one of two things. One is that the exposure even I
10 I without the respirator is very low anyhow and f ar below the 11 limits anyhow, so it is just an ALARA practice that we shouldn't 12 regulate that closely anyhow. ,
13 Or else, convince him that it would be so costly to 14 keep the radioactive matter out of the air that they would have !
15 to shut down the plant. If they can convince the inspector of 16 that, it is true, they are allowed to use the respirators.
1 17 VOICE: I think one variable we haven't mentioned ;
i 18 is the degree of convinceability of your inspectors.
19 MR. ALEXANDER: Well, tnat is a problem that I l l
20 guess every government in every country in every time in history 21 has had, when you have a regulatory program and depend on the l 22 inspectors, it is just like a football game and the zebras.
23 Sometimes they make a bad call. Usually they call them right. ,
i 24 MR. CAPLIN: Also, this part of the regulation really!
>Facw:l Rmoners, inc. I 25 i is relatively new. Some of those operations had been going on !
101lI ari 10 1 probably for somo time. There is a question also whether you 2 are talking about inspection or design for new places. I think 3 in looking at licensing for new places that are being designed, 8
4 the licensing people would have a different regulation than 5 they are looking at now from the one that existed when some of 6 these people were originally licensed.
7 MR. ALEXANDER: I think what we better do is get 8 back! to this list of gyestions, or I will leave it up to you.
t 9 Let me ask if anybody has any more points they would like to j i
10 make to Alan Roecklein about these questions.
11 VOICE: What about some written responses there, too, 12 rather than try to do it all here right now.
13 . MR. ALEXANDER: We would welcome that.
14 MR. ROECKLEIN: Yes.
15 MR. ALEXANDER: Sure, we would welcome that.
16 MR. ROECKLEIN: Do you need more copies of the 17 questions?
l l
18 VOICE: No, I don't think so. I just was thinking l 19 that I might think of something else af ter I leave the room.
20 MR. ROECKLEIN: That would be very helpful.
21 VOICE: I would like to say a similar thing. ,
22 MR. ROECKLEIN: Yes.
23 VOICE: Several people mentioned their problem with l
24 the level of understanding. They want to be sure it is easy l D-Fmwel R porars, inc, l 25 to understand it. We worked really hard on making the -- we !
I l
102 jeri 11 ; want to know whether you think that is easily understood..
2 Have you had a chance to look at it? If you think it is too 3
hard, let us know.
4 VOICE: I think it is difficult in responding to 5 that without going to somebody else because if you come into 6 a situation where you already have a little bit of knowledge 7 or some relative knowledge about the subject to begin with, 8
it might be pretty easy for you to understand. You say, okay, 9 it's easy. But then I would rather check with somebody else 10 and see what they thought about it, too.
11 MR. ALEXANDER: We want to do that. The technique 12 we used on 8.13 which we. never tried before, was I put a health 13 physicist on it and said, now, you write it as simply as you 14 can. And I knew when he brought it back that it wouldn't be 15 ' intelligible to a novice. So then we brought in a female who '
16 didn'.t know anything about radiation but who was -- who is a ,
17 very good writer. In fact, she makes her living as a technical i 18 writer correcting other people's writing. We had her rewrite 19 it. Of course, when she brought it back you could understand 20 it but everything was. wrong.
21 So then I locked them in a room and they came out 22 with a guide which our boss described as the first one he'd 23 ever seen that was written in English. j l
c 10 24 ,
MR. JOY: Very good. Now you understand our problem.;
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1516.#1,1 arll 103 1
VOICE: On this' Question.27, how is worker radiation 2
exposure determined? You brought that out at the introduction, 3 if I am not mistaken, about getting somebody or some organizationi 4 to.be a little more specific and a little more determining.
5 the workmanship of giving the problem the correct' amount 6
f exposure _that person received.
7 I am talking about processing that film badge 8
and so forth. People over there were talking about getting 9
the amount, full amount, maximum amount, the minimum, and so 10 forth and so on, whatever. That has a lot to do with7 who is 11 processing that film.
12 ,
MR. ALEXANDER: Sure, it does.
13 VOICE: And whether he's got -- he received none, 14 or three has a lot to do with that person that processes, 15 whether he is going to keep working or whether he will not 16 keep working.
17 Personally, myself, we have run a hell of a~ lot of 18 that. I know myself that some film badges are not 19 properly processed. And a man loses his job with that amount.
20 Naturally we take it to the usual procedure, arbitration; by the time we come to conclusion, the man is finished.
21 22 He can't go back to his job.
23 I think we ought to concentrate a hell of a lot on
-24 who determines what dosage a person receives, any possible.way ;
p .e r.i nroeree,3,inc.
25 for that film badge or whatever, the safety devices has to be --l l
1
.ar2' 104 l I
I believe in your case whoover does that ought to be super-2 vised much more strictly than they are.
3 MR. ALEXANDER: I mentioned to you the pilot test d
study that we have being conducted by the University of 5
. Michigan and what we got there is virtually every dorimetry 6
processor in the country is participating in having his 7
dosimetry tested.
8 I mentioned to you that the results are disappoint-9 ing. It is in the Public Document Room, the last progress ,
10 report. You can check it out and look at it if you want to.
II 78 percent of the processors are failing. So it is not -- l 12 MR. JOY: 78 percent are failing?
13 MR. ALEXA'; DER: It is not a measurement technique l#
that is in very good shape. We are moving as rapidly as we 15 '
can toward regulations which will correct that.
16 Now you are bringing that up in terms of Question I7 27, how is worker radiation exposure determined. It seems l
18 to me that the question you are raising is whether or not the 19 NRC in its answer to that question ought to be frank about 20 the accuracy problem. I tend to think that we should. I 21 think that it is not so good to have these workers thinking 22 they have got something that is really accurate that 23 they are wearing around when some of us know that they are not ,
24 l
so accurate in every case and that we ought to be frank about, i
).Fooerd Reporters, Inc.
25 at least to some extent, about that problem.
I 1
- ar3 105 1 . VOICE: 101at is the degree of discrepancy? How 2 off can I be if mine says I received 5 rems?
3 MR. ALEXANDER: The' criterion being used, which was 4 developed by the Health Physics hciety'.StandardsCommittee,.
i.( p 5 is right around 20 percent, plus or minus 30 percent. If A
6 the dose gets lower, as the dose gets lower, that 30 percent 7 that is allowed gets bigger.
8 VOICE: How bad are they failing? Are they failing 9 'with 50 percent, 60 percent? How far off that 30 percent 10 limitation are they?
11 MR. ALEXANDER: I don't know. All I am getting so t
12 far are progress rerorts which haven't -- which have only 13 given an example of one or two processors. Those processors 14 weren't failing by very much, but they were failing, and 15 they were failing some criteria that don't seem to be too 16 stringent. It just looks to us like something that needs to 17 be tended to, and that the government ought to do it. ;
18 VOICE: Do you have jurisdiction over the processes?
19 MR. ALEXANDER: We don't have jurisdAction over the 20 processes unless the licensee is doing it himr ;t what 21 we can do is tell that licensee that he's go' grove to us 22 that his dosimetry was performed by a processor that 23 successfully passed these criteria a couple times a year or l
24 three times a year, whatever the Commission decides. I think i
>Feoeret r,ecorters, Inc.
25 we will have that regr*Leion in force before too long.
l 4
ar4, 106 I
The only thing is we havo got to make sure ws have 2
good criteria to go by or we will put everybody out of business.
3 Then there wouldn't be anybody to do any dosimetry. We 4
have to do this carefully.
5 VOICE: Are they checked on the film badges, Bob?
0 MR. ALEXANDER: Yes, that is what I am talking 7
7 about, film badges, and fLDs, and pocket dosimeters.
8 VOICE: Both things?
9 MR. ALEXANDER: Yes.
10 Let me ask the other unions represented here 11 what you think about talking very much about that particular 12 problem in this guide on risk.
13 This gentleman -- I am sorry, I can't seem to get Id the name.
15 MR. BAKODY: Bakody.
16 MR. ALEXANDER: What do the rest of you think l l
17 about going into some detail on that one on this guide? l 18 MR. SHOOP: I would back off, Bob, because we do 19 get questions. Some of our employers use three different 20 systems. The correlation is not the same, one for one for one, 21 on all three. I think this would raise another issue you are 22 alreading correcting.
23 VOICE: You know, we want to get this so that we are 24 not raising more questions than we are answering. If you get ,
a Focerd f.epomn, Inc.
25 what I mean. On this I don't have an opinion to the specific l i
l
, cr5 107 1 question. But wa are getting -- DOE, not you -- wa are 2 .getting discrepancies of up to 10 on them.
3 JUL ALEXANDER: That is really low level, isn't it?
4 VOICE: No, it is not that lo.w level. In other words, 5 .are you going to'believe the guys are getting 5 rems, or-6 157 7 MR. ALEXANDER: I haven't seen any that bad.
8 VOICE: It is not in your' agency so we are not 9 accusing you of maything.
10 VOICE: I would think the more questions, the better ,
11 especially amongst ourselves, rather than an outsider say, 12 well, why didn't you ask this question? I would rather put 13 any question on the table and kick it around and back off on '
14 nothing, because once you back off, someone else will come l 15 in and say why did you back off, an'd they will figure there 16 is a hidden meaning that you are backing off.
~
, 17 MR. ALEXANDER: People often ask that question.
18 Almost every discussion I am in, that question comes up.
19 Even ene of the Commissioners the other day raised the question, 20 how accurate are these badges. So maybe it is one we ought ;
21 to deal with.a little bit, Frank.- And just indicate that :
22 they are not absolutely accurate. ;
I l
23 MR. BAKODY: Out in the field that is all we can i 24 -depend on. A dosimeter and film badge. That's all we have got.. :
pFwral Roorms, lm. l 25 alive to' depend on. Of course, we are minute compared to a i: ;
1 nuclear plant, but one life in still one. life. You can't 2 say, well, just-because'you are one and I am'100, forgetLone.
3 You.can't'do that.
No, we" don't.do that.
4 MR.' ALEXANDER:
5 MR..BAKODY: I am talking about as overall in this l 6 room. A question, if there is a, question. arisen that_we have 7 to consider this,.this is my feeling. This is all we have 8 to depend on for safety. l I
9 MR. ALEXANDER: I will tell you what we will do.
10 We will.take a crack at these answers and let you have a look 1
11 at them before we publish them. 1 4
12 MR. JOY: Could I ask on that topic, we got an
.13 idea what it is about today, got a little more info'rmation. ,
14 Instead of writing, I understand writing, you can't argue 15 with a writer -- is there any possibility we have one more 16 meeting before you start publishing?
17 MR. ALEXANDER: Yes; sure.
18 MR. JOY: That we can get through this again. ;
19 I would like to sea maybe a sketch of what the guide would be, ,
20 maybe we can go into'it in a little more detail.
21 MR. ALEXANDER: Maybe'the best way to do~that 22 would be, as soon as we get the initial draft ready, to let 23 you have it. Then have another meeting a couple weeks after 24 that. ,
- Fooeres Reporwes, loc.
'25 MR. JOY: That's good.
4 i
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'ar7 I
MR. ALEXANDER: After you have looked at our questions, we will give you a look at our answers and get b'ack together.
VOICE: Then we can take those apart.
3 MR. ROECKLEIN: Good.
0 MS MAC DONALD: 1 think really some of the points 7
you raised here are pretty important, and we will have to think 8
about them. This question of accuracy, if you don't want to 9
terrify them, you have to give them a break on the other. If 10 you have inaccurate equipment'to measure dosage. Should 11 some equipment be developed in a year that is much more 12 accurate, it is going to make us all look terrible, for one
~
I3 thing.
MR. ALEXANDER: It is not that bad.
1 *5 MS. MAC DONALD: It looks bad. If you are talking 16 about tenfold error --
II VOICE: That was comparison of what we calculate I8 what dose should have been and what the badge said it had 19 been.
20 MS. MAC DONALD: Regardless, I think we need to 2I reconsider the amount of information that should be developed.
22 MR. ALEXANDER: This is really a key question, 23 the accuracy problem. Some of you may have heard that the 24 '
>Focoril Reporters, Inc.
Congress is interested in funding a big study about effects 25 on workers, going back over their records for many years like
, ar8,. 110 1 Mancuso did. And coming up with the answers. All of these 2 people _ that' are thinking about the funding and so forth, I 3 don't think anybody's bothered to tell them that the dosimetry 4 data isn't perfect.
5 If you find an increase of a half of 1 percent in a i 6 large group of people using instruments that are only -- that 7 aren't even close to the true dose, why, what have you got?
8 So it is an important question. The question he's raising 9 is shall we hide this from the workers or shall we tell it 10 like it is in the guide.
11 VOICE: Don't hide nothing. , ,,
12 MR. JOY: Tell it like it is. That's the way it is.
13 VOIDE: You have got to give us more facts than a 14 broad 78 percent are inaccurate, you know.
15 VOICE: You better come up with a better badge, 16 Bob.
17 VOICE: That's the point I wanted to get back to.
18 We don't want to try to deal with things in the guide, 19 necessarily, that should be dealt with by NRC. If a badge 20 is not good, we should do more than just tell the workers 21 that they are not good.
22 MR. JOY: We should knock it right off the market.
23 VOICE: If they have a degree of inaccuracy, that is 24 not good, we.ought to say to NRC, this has got to be a high m-Feders Aeoorters, Inc.
25 . priority item on your agenda.
!~
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, ar9, 111 l
1 VOICE: As I understand it, though, it's'nothing 2 wrong with the device, it is the processing.
3 VOICE: Yes, that is what I got.
4 VOICE: The device --
5 MR. ALEXANDER: That's one of the things we are 6 trying to pinpoint. One of the things our contractor is 7 being paid to do in his contract, he's told when a processor 8 does poorly, to get with him, work with him, find out why, 9 help him straighten it out. After they have gone -- see, 10 they are only through the fkrst round so far. Nobody's had a 11 chance to get things straightened up and see how much better 12 he can do. That is starting now. So at this point I really
'13 don't know whether it is the -- whether it is inhere,nt problems M /// A h/[4 Us a !
14 with the si4a supplied by the, FLD suppliers , whether the 15 technology is poor, whether it is in the processing, or 16 what the problem is.
17 I do know that I -- I can say that some of those !
I 18 processors are doing it beautifully. They are just-within 4 19 or 5 percent on the badges. Taat indicates to me some people 20 need to learn how to do it, that it can be done with what they 21 have got.
22 VOICE: Is there any thought to having technicians 23 do it? They don't have technicians doing it in our plants.
24 That is one of the questions raised by the committee, that i' O.F.e.r.: r.epe n m ,inc.
25 they are clerks that may not even be familiar with the terms. j l
I
. ar10, 112 1 MR. ALEXANDER: Well, wo~cre going to have to find 2 out where the problems are.
3 VOICE: I mentioned badges before. I was thinking i
! l 4 of a dosimeter, what we refer to as what you look for. Our l l 5 people seem to be more comfortable with the badge.
6 MR. ALEXANDER: They place more confidence in the l 7 badge.
8 VOICE: Yes, than what I refer to as the dosimeter, 9 -what you look through. ,
I 10 MR. ALEXANDER: I think that's always been the case.'
11 VOICE: I think so. That is why I was asking is 12 this the badge, or just a general thing that took in the 13 dosimetry, rather than the reliability of the recording.
14 Which is it? Is it the recording of it or the reliability of 15 actually the way it registers? Between the badge and the one 16 you look through? - -
17 MR. ALEXANDER: Well, the badges are more responsive' l
18 to low energy, to the low energy component of the radiation !
l 19 field, than most of the pocket dosimeters. So usually the 20 pocket dosimeters read a little bit lower than the badges. l 21 That is why people prefer to go by the badges.
22 VOICE: The badge, yes, they do. But again that 23 technician point is something they have been raising, using 24 clerks recording it after reading it. l fwpol Roorwrs, lm.
25 MR. ALEXANDER: I am not sure I understand how you aye
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113 aril I
using the word tnchnician.
2 VOICE: Well, we would say a health physics 3l technician should be doing the work with that rather than ;
I d
giving it to a clerical person.
5 MR. ALEXANDER: I see.
6 VOICE: Because they are not satisfied with the 7 readings that are coming out. When they get their records, 8
they are comparing it to the number of hours they worked with 9
another fellow, and those may show a lot lower than what his l 10 shows,. and they work almost as a team. Or there are only 12 11 or 13 of them involved in the work, and they are all working 12 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a week in the same locations.
I3 MR. ALEXANDER: The next time we get together, Id maybe I will have some answers. .
I 15 VOICE: I will get more information on this, too.
16 MR. ALEXANDER: All I can report to you today is that I7 'he results are not very encouraging.
. But that we do have a '
l 18 very active program to get it straightened out. Thk. Is !l 1 l 19 something that will be handled through the regulations. l 20 VOICE: That is one of the big problems, the l 21 credibility of the entire thing, that they are using. We 1
22 had that with instruments that they were using for gases and
, 1 23 other things they weren't too confident with, and alarm ! ,
24 !
systems and many things that that committee can bring up, as punacwomn.w.
l 25 l you know, when you are sitting there speaking to them, the l l I
I
arAe 114 ll
' i I
devicos that are used.
1 I
2 MR. ALEXANDER: One of the things on Question 29 3
I failed to mention, what Question 29 is all about, that says : I I
i 1 4
where can I get additional information on radiation risk, that i 5 isn't just going to be a list of books.
6 We are going to give an address to write to or 7 telephone number to call. Any worker who is not satisfied 8 with what he gets here or what the instructor tells him, and 9 we will talk to the guy on the phone. '
I 10 MR. JOY: Bob, we are going to have to go. l I e i
Il appreciate everything that went on and look forward to the 12 next meeting.
13 MR. ALEXANDER: I am glad you could come. I think 14 it's been a good meeting.
15 MR. JOY: Excellent.
16 MR. ALEXANDER: It's probably the sort of thing ;
17 we ought to do more of on some of these sensitive areas.
18 (Whereupon, at 1:05 p.m., the meeting was j 19 adjourned.1 20 l i
21 -----
22 23 i i
24 D4M9fsl ARDoriers,1N, 25 ~ ,
e
. . Iderble 8 d MEETING: NRC Staff and Union Representatives
SUBJECT:
PREPARATION OF REGULATORY GUIDE ON RISK FROM OCCUPATIONAL RADIATION EXPOSURE TIME & DATE: 9 a.m., Tuesday, November 28,1978 PLACE: Conference Room P-ll8 Phillips Building 7920 Norfolk Avenue L'ethesda, Maryland AGENDA 9':00 a.m. Introduction (R. E. Alexander) 9:15 a.m. Proposed Scope of Risk Guide (A. Roecklein)
@- Suggested Format (Reg. Guide 8.13, enclosed) h- Major topics
@- Alternative forms for appendix Text (as in 8.13)
Question and Answer format Programmed Self-Study text Audio-Visual presentation
@- Discussion of suggested questions for append'x -
to Reg. Guide, to be forwarded to you prior ,o the meeting.
l l
l l
l
s . . ,
J The following questions represent the tentative format of the Appendix to proposed Reg Guide 8.JC (Instruction Concerning Risks from Occupational Radiation Exposure). They are presented here as an outline for discussion. ;
- 1. What is meant by risk? - -
- 2. What are the biological effects of exposure'to radiation?
- 3. How do we define different kinds of effects such as prompt effects, delayed effects and genetic effects?
- 4. As nuclear industry workers, which effects should concern us most?
- 5. What is the difference between acute and chronic exposure?
- 6. How does radiation cause cancer and other effects?
l
- 7. If I receive a radiation exposure does that mean I will develop i cancer? !
- 8. Can a worker exposed to radiation beccme sterile? Impotent?
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- 9. How can we estimate the risk- from radiation exposure?
- 10. How can we compare radiation risk to other kinds of health hazards?
- 11. How does the occupational radiation risk compare to occupational risks in other industries?
- 12. How does the accident rate at nuclear facilities compare to other industries?
- 13. What are the NRC radiation exposure limits?
- 14. What is meant by ALARA?
- 15. What is the collective dose and why should it be maintained ALARA?
d
- 16. How are radiation exposure limits established?
P
- 17. What are the normal radiation exposures received by workers?
- 18. What happens if a worker exceeds the quarterly exposure limit? the ;
1 annual limit?
- 19. Why do some facilities establish administrative limits which are below the NRC limits?
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- 20. Several scientists have recently suggested that NRC limits are too '
high and should be lowered. What are the arguments for lowering the limits? .
- 21. What are the arguments against lowering the limits?
- 22. How would you describe the NRC position on exposure limits?
- 23. How much radiation does the average person receive who does not work in the nuclear industry?
- 24. Why aren't medical exposures considered as part of a worker's allowed dose?
- 25. What is meant by internal. exposure?
- 26. Is internal exposure included in a worker's allowed dose?
- 27. How is a workers radiation exposure determined?
- 28. What are my options if I decide not to accept the risk of radiation exposure?
- 29. Where can I get additional information on radiation risk?
3
.z .
i PRINCIPAL DOCUMENTS FOR OCCUPATIONAL HEALTH PROTECTION i ISSUED BY THE NRC OCCUPATIONAL HEALTH STANDARDS BRANCH Title 10, Chapter 1, Code of Federal Regulations, Part 19, " Notices, Instructions, and Reports to Workers; Inspections" Title 10, Chapter 1 Code of Federal Regulations, Part 20, " Standards for Protection Against Radiation" Regulatory Guide 8.1, " Radiation Symbol," issued 2/2/73 Regulatory Guide 8.2, " Guide for Administrative Practices in Radiation Monttoring," issued 2/2/,73 Regulatory Gu'ide 8.3, " Film Badge Performance Crite'ria," issued 2/2/73 Regulatory Guide 8.4, " Direct-Reading and Indirect-Reading Pocket Dosimeters," issued 2/26/73 :
Regulatory Guide 8.5, "Immediate Evacuation Signal," issued 2/16/73 Regulatory Guide 8.6, " Standard Test Procedure for Geiger-Muller Counters,"
issued 5/73 Regulatory Guide 8.7, " Occupational Radiation Exposure Records Systems,"
issued 5/73 .
Regulatory Guide 8.8, "Information Relevant to Ensuring That Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable," Revision 3, issued 6/78 .
Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations , and Assumptions for a Bioassay Program," issued 9/73 Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Radiation Exposures As low As Is Reasonably Achievable," Revision 1-R, issued 5/77 l
Regulatory Guide 8.11 " Applications of Bioassay for Uranium," issued 6/74.
Regulatory Guide 8.12. "Ci'iticility Accident Alann Systems," issued 12/74 Regulatory Guide 8.13, " Instruction Concerning Prenatal Radiation Exposure,"
Revision 1, issued 11/75 l
\
Regulatory Guide 8.14. " Personnel Neutron Dosimeters," Revision 1, 8/77 Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection," )
issued 10/76
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Regulatory Guide 8.18, "Information Relevant to Ensuring That Occupational Radiation Exposures at Medical Institutions Will Be As Low As Reasonably Achievable (For Comment)," issued 12/77 Regulatory Guide 8.19,'" Occupational Radiation Dose Assessment in Light-Water Reactor Power Plants--Design Stage Man-Rem Estimates (For Comment),"
issued 5/78 Regulatory Guide 8.20, " Applications of Bioassay of I-125 and I-131 (For Comment)," issued 4/78 Regulatory Guide 8.21, " Health Physics Surveys for Byproduct Material at NRC-Licensed Processing 'and Manufacturing Plants (Ear Comment)," issued
.5/78 Rpgulatory Guide 8.22, " Bioassay at Uranium Mills (For Comment)," issued -
7/78 Regulatory Guide 10.1, " Compilation of Reporting Requirements for Persons Subject to NRC Regylations," Revision 3, issued 5/77 Regulatory Guide 10.2, " Guidance to Academic Institutions Applying for Specific Byproduct Material Licenses of Limited Scope," Revision 1, issued
- 12/76
, Regulatory Guide 10.3, ' Guide for the Preparation of Applications for Special Nuclear Material Licenses of Less Than Critical Mass Quantities," Revision 1, issued 4/77 Regulatory Guide 10.4, " Guide for the Preparation of Applications for
- Licenses to Process Source Material," Revision 1, issued 3/77
. Regulatory Guide 10.5, " Guide for the Preparation of Applications for Type A Licenses of Broad Scope for Byproduct Material (For Comment),"
issued 9/76 Regulatory Guide 10.6, '.' Guide for the Preparation of Applications for Use of Sealed Sources and Devices for the Perf6rmance of Industrial Radiography (ForComment)," issued 9/76 Regulatory Guide 10.7, " Guide?fortthe Preparation of Applications for Licenses for Laboratory Use of Small Quantities of Byproduct Mate' rial (ForComment)," issued 2/77 i a i
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REGULATORY GUIDES UNDER DEVELOPMENT:
- Bioassay for Tritium
- Radiation Protection Training at Nuclear Power Plants
- Health Physics Surveys at Uranium Fuel Fabrication Plants t
- Bioassay for Fission a'nd Corrosion Products
- Health Physics Surveys at Medical Institutions
- Radiation Protection Training at Uranium Fuel Fabrication Plants
- Qualifications for Radiation Safety Officers of Large-Scale Programs
- Alarming Pocket dosimeters i'
- Preparation of License Applications for Medical Uses of Byproduct Material !
- Health Physics Programs for Ura6ium Mills
!
- Preparation of Applications for the Use of Gamma Irradiators l I
t i
REPORTS:
WASH 1251, " Applications of Bioassay for Uranium," R. E. Alexander, published 6/74 NUREG-0041, " Manual of Respiratory Protection Against Airborne Radioactive Material," Jerrold Caplin, published 10/76 NUREG-0419, " Occupational Radiation Exposures at NRC-Licensed Facilities 1975 Walter S. Cool, published 3/78 NUREG-0444, "BEIRM00, A Computer Program for Calculating the Effects of Exposure to Ionizing Radiation," C. A. Willis, published 5/78 NUREG-0267, " Principles and Practices for Keeping Occupational Radiation Exposures at Medical Institutions As Low As Reasonably Achievable," Draft, A. Brodsky, published 12/77