ML20154M634
| ML20154M634 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/1988 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20033D967 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8809290048 | |
| Download: ML20154M634 (119) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION !
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Title:
BRIEFING ON STATUS OF EFFORTS TO DEVELOP A BELOW REGUI.ATORY CONCERN POLICY ,
i Location: ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND i
! Date: FRIDAY, SEPTEMBER 16, 1988 i
i Pages: 1-73 ,
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i2 890?16 P r o. 7 roc Ann Riley & Associates f Court Reporters 1625 i Street, N.W., Suite 921 Washington, D.C. 20006 f (202) 293-3950 -
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i DISCLAIMER -
This' is an unof ficial transcript of 'a meeting '
of the United States Nuclear Regulatory Commission held on September 16, '88 tn the Commission's office at One White Flint North, Rockville, Maryland. The meeting was open to public attendance and observation. This transcript has not been ~ rev'lewed, corrected or edi ted, and. i t may contain inaccuracies.
The transcript is intended solely for general informational purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript !
do'not necessarily reflect final determination or beliefs.
No pleading or'other paper may be filed with the Commissign in any proceeding as the result of, or addressed to, any statement or argument contair.ed herein, except as the l Commission may authorize.
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g 1 1 UNITED STATES OF AMERICA
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2 ,
NUCLEAR REGULATORY COMMISSION 3
BRIEFING ON STATUS OF EFFORTS TO DEVELOP 4 A BELOW REGULATORY CONCERN POLICY 5
6 PUBLIC MEETING 7
9 9 Nuclear Regulatory Commission One White Flint Nvrth to Rockville, Maryland 11 Fridcy, September 16, 1988 12
- 13 The Commission met in open session, pursuant to 14 ~ notice, at 10
- 00 a.u., the lionorable LANDO W. ZEC'.1, Chairman 15 of the Commission, p residing.
16 17 COMMISSIONERS PRESENT:
18 LANDO W. ZECH, Chairman of the commission 19 TilOMAS M. ROBERTS, Member of the Commission
- 3) KENNETli M. CARR, Member of the Commission 21 KENNETli C. ROGERS, Member of the Commission 22 23 24 M
-~ - -- - ,
4 2 1 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
2 3 A. BATES 4 W. PARLER 5 V. STELLO, JR.
6 b. MORRIS 7 W. LAHS 8 11 . THOMPSON 9 F. CONGEL 10 R. ALEXANDER 11 L. TAYLOR 12 T. TIPTON r 13 14 16 16 17 18 1
19 20 21 22 23 24 i
i 6 3 1 PROCEEDINGS 2 (10 :00 a .m. )
3 Cl! AIRMAN ZECH: Good morning, ladies and
,4 gentlemen. The purpose of this mornings briefing is for the 6 Commission to learn of the NRC staff's progress in 6 formulating a policy in the area of below regulatory concern 7 for practices whose public health offects and safety impacts 8 should be below a threshold level of regulatory concern.
9 I understand that the staff proposes that the l
10 Commission approve for discussion its draft policy statement 11 at an NRC-sponsored international workshop on exemptions from 12 regulatory control for practices where public health and 13 safety impacts are below regulatory concern. This workshop 14 is currently scheduled for october 17th through the 19th.
to . I would ask today that the NRC staff include for 16 discussion during the workshop any topics that are raised by 17 the Commissioners during this mornings meeting. I believe 18 that the Commission should reach its final dec!sion -- I 19 cmphasize final decision -- on the staff's proposal following M the conclusion of the staff's evaluation of public comments 21 and the results of the international workshop. In other 22 words, after the public comments and then after the 23 international wockshop.
24 After hearing the staff's briefing this morning, .
25 i suggest that the Commission censider the possibility of
- 4 1 agreeing to support the staff's using their draft policy I
2 statement or any modifications that we might suggest as a 3 basis for discussion at their forthcoming international 4 workshop.
5 I also suggest that the Commission consider 6 requesting public comments on the proposed policy including 7 issues raised by the Commission here this morning, a The Commission this morning will also hear from 9 Doctor Lauriston Taylor, Chairman of the Health Physics to Society work group on below regulatory concern, presenting 11 the views of the Health Physics Society on this subject.
12 Additionally, the Commission will hear from Mr. Thomas Tipton 13 who will present a brief summary and statua on industry 14 efforts on radiation risk which are below regulatory concern.
15 I understand there are copies of the view graphs availabic r
16 at the entrance to the meeting room.
17 Do any of my follow Commissioners have any opening 18 comments that they would like to make before we begin?
19 (No response.)
XI CHAIRMAN ZECH2 If not, Mr. Stello, you may proceed.
21 MR. STELLO: Thank you, M't . Chairman. The subject 22 we want to discuss this morning is certainly not an easy one.
23 It is indeed very, very complex for which there are a variety t
24 of views of how to proceed. That variety of views exists
- i '
M within the staff as well as -- if you have road much of the e
i e
. . 5 1 literature -- the debate is considerable within the technical t
2 community.
3 I think there is an element of this approach we are 4 following that deserves a little bit of comment up front in 5 terms of getting a broad picture. That has to do with 6 setting two particular elements to describe an area wherc 7 we wt.uld suggest is an appropriate policy for below regulatory 8 concern. One is to try to establish admittedly a fairly 9 small number in terms of units of millirem -- the ten 10 millirem that is in the paper -- as well as a collective dose.
11 The :ollective dose is one for which there is in fact 12 co siderable controversy and I am sure you will hear more 13 about that this morning -- at least I have heard a' great deal 14 about it from some of the scientists who argue that that 15 len't the way we ought to go -- but one for which there is a 16 considerable procedent within the Agency as a tool that wo 17 have used that dates back to the ALARA concept starting back 18 I guess with the very extensive hearings in 1971 I think, and 19 it has been embodied within a great deal of the regulat,ry M approach that we have used over those years.
21 I think because the precedent is there that we are 22 obligated to still consider it but I think it has two 23 reasons. One is that is where you go when you look at how 24 you do the calculations based'on extrapolation of the data M collected of the radiation effects from the bombs, You
. 6 1 extrapolate to low exposures and then you integrate under a 2 curve to get the cumulative effects.
3 But there is another aspect of that and that is 4 we have established a $1,000 a person rem. And, if you look 5 at the bounds of what we have put in the table, it suggests 6 that for a 100-person rem exposure at $1,000 a person rom 7 about $100,000 in almost any kind of analysis that we would a undertake and the resources that we would devote. It also 9 suggests that that is cnother policy call as to whether it to is well worth the time and the effort and the energy of 11 spending additional analyses to get further in there because 12 analyses, by itself, cost money and take resources. It also 13 is the precedent.
14 So, I think there is some history and rationale 15 behind the approach that we take that is going to be one for 16 which considerable thought needs to go into the process but 17 what we really want to do is to start the process, to start 18 the comment, to start the debate, and then come to the 19 Commission after that debate has had a chance to go on, and 20 we can collect that kind of information and then come back 21 to tbc Commission and say we now think we have got a policy.
22 that has the benefit of the input from every word that it 23 ought to have and then can come to the Commission with far 24 more confidence that we have a reasonable approach.
25 So, we are not here today to.tell the Commission O
- 7 1 that we think we have the final answer for the Commission.
2 To the contrary, we dsn't, but we think we have a reasonable 3 approach if the Commission agrees it is a reasonable approach 4 to start this debate, to start this discussion and engage 5 the scientific community to the best of our ability to do so 6 to cornment on this kind of policy.
7 With that background, let me ask Bill Morris to go 8 through the presentation for us this morning. And, we will 9 be mindful of the comments the Commission raises this 10 morning to be sure that as we continue to get into this 11 issue that we have considered all of the issues that will be 12 raised here this morning.
13 Thank you, Mr. Chairman.
14 CHAIRMAN ZECH: Thank you very much. Proceed.
15 MR. MORRIS: Thank you. On the first page of the to handout, it provided an outline of the presentation plan for 17 today. It covered the purpose of this presentation, the 18 background, went into the objective of the policy statement 19 and some of the basic considerations that have been in the M staff's mind as they developed the policy, covered the key 21 elements of the policy statement and briefly mentioned our 22 plans for an international workshop.
U (Slide.)
24 i MR. MORRIS: In addition, i f t ime pe rmit s , I will D provide a brief discussion of the major issue raised in the I:
. 8 1 ACNW letter that was issued yesterday.
r 2 On page two --
3 (Slide.)
4 MR. MORRIS: -- I note that the purpose of the 5 presentation is to discuss this proposed Commission policy 6 statement which would be the basis for decisions on 7 exemptions from regulatory control for those practicca with 8 such small health and safety impacts that they may be g considered below regulatory concern. As I said, we will go 10 into the workshop very briafly.later on.
11 The next page --
12 (Slide.)
( 13 MR. MORRIS: --
I note that the Commission sent 14 out a staff requirements memorandum on March 30th of 1988 15 which directed the staff to submit for Commission to consideration a policy statement and options which establish
- 17 a generic number for exposures that are below regulatory 18 concern.
gg In SECY-88-257 a draft proposed policy statement 3 was provided by the staff. Included among the enclosures i
21 are discussions which provide perspective on policy options l 22 other than those proposed by the utaff but which the 23 Commission may wish to consider in its deliberations. In 24 addition. we included a discussion of the uncertainties in 25 the risk dose data base that was of interest to the
0 9, 1 Commission.
2 As Mr. Stollo said, once we get the Commission's 3 guidance regarding your views on this subject of c proposed 4 policy statement, issues you are interested in, we will 5 proceed to discuss this at an international workshop and 6 prepare to issue the policy for public comment.
7 on page four of the handout --
8 (Slide.)
g MR. MORRIS: -- we note that the objective of the to policy statement is to establish a basis for development of 11 regulations and for making licensing decisions. These would 12 define conditions for exemption of certain practices from 13 regulatory control. Specific rulemaking applications that l
14 are currently planned or envisioned include disposal of low 15 1cvel reactor waste streams, radiological criteria for de-16 commissioning of lands and structures, radiological critoria 17 for release of materials and equipment.
18 It is also expected there may be other applications 19 if new consumer product exemptions are proposed. These could
- 3) also be granted based on the elements of the policy. Once 21 the new regulations are in place, individual licensees would n only have to demonstrato compliance with the conditions of 23 the exemption. That is something, for instance, say a 24 volume concentration level of various isotopes would be the 25 condition on which some material could be released in our
. 10 1 reactor wasto stream.
2 Itaving donc that, they would be taking advantago 3 and we would be taking advantage of tho' policy and the case 4 with which we would be able to then go forward and release 5 this material.
6 On page fivo --
7 (Slido.)
8 MR. MORRIS: --
I wanted to go over some of thoso 9 basic considerations that the staff has been attentive to as to it has developed thin policy. Thnre are three f undamental 11 principles of radiation protectio'. that we have based the 12 policy on. The principle of justification of practico is 13 casentially the concept that there should be no deliberate 14 exposure to radiation or release of radioactive materials 15 from licensed or exempt activities which does not provide 16 some benefit to society.
17 The reason the staff recommends that this principle 18 of justification be incorporated into the policy statement is 19 to clarify the Commission's intention to make such judgments ,
M in implementing those exemption decisions.
?! We have also used the concept of radiation doso M limits which, by the way, are included as the basic D radiation protection standards in 10 CPR Part 20. In the 24 proposed revision of Part 20,which is moving through the j i :
25 concurrence process within the staff now, the maximum allowed l
b
I o 11 g annual dose to a member of the public in 100 millirem. In 2 granting exemptions under the proposed policy, our casic 3 objectivo is that by no means should an individual roccive 4 a cumulative dose greater than this value when all tho 6 licensod or exempt practicos -- that is multiplo exposures --
6 are taken into account.
1 In fact, the goal that the staff would have in mind a would be that such doses would bo well below 100 millirem.
9 Lot roe clarify that for each licensuo the licensee is expected to t's mon i to r 41..* take measuros to provide that assurance but 11 uhen you exempt the practice and there la some reduction of 12 t'ontrol or essentially a loss of control of the material,
- s then there is no monitoring. It is only up to the judgment 14 of the Concission in developing a policy like this that you 15 would be ass.uring that those doses ot multiple' practices 16 remain below 100 millirem.
17 As Mr. Stello pointed out, a longstanding element 18 of radiation protection is the concept that in addition to 19 the basic radiation protection standard, such as the 100 20 millirem limit on annual doso, the concept of ALARA is 9
21 applied. That means that you want enhanced protection beyond 22 the limit. In applyi.ng ALARA, it has been traditional that 23 we do cost benefit' tradeoff analyJes to determine when doces 24 have been achieved which are as low as reasonably achievable 25 which is ALARA, And. the reasonable part pertains to those l
I
.. 12 1 analysos and judgments that one makes to determino how far 2 one should go in reducing dosod.
3 In addition to the concept of cost benefit 4 tradeoffs in order to attain an ALARA level, the concept 5 also exists and one that has been developed further in this 6 policy that you can decido that doses and risks are ALARA 7 jut because they are suf!iciently small that they don't 8 warrant further attention. ,
9 To go on to page siX --
i
, 10 (Slido.)
11 MR. MORRIS: -- another hasic concideration that we 12 had to take into account au we developed this policy was tho 13 relationship between radiation dos.: and tiuk. The risk 14 estimates in the policy are based on the lir.a.+r non-threshold 15 relationship between dose and risk. In enclosure five of 16 SECY-88-257, the staff provided a discussion of the 17 uncertainties assoc.iat2d with the linear non-threshold model. l 18 This discussion that we provided is primarily baced on the ;
i 19 BEER-3 report. It highliyhts the unavailability of M cpidemiological data in the low dose range and uncertainties ,
21 in the .ata bara from the atomic bomo explosions in Japan.
22 Specif4cally with regard to the lattor, I should ;
i 23 point out that there is a re-evaluation of the dosimetry 24 from the bomb data that is expected to result in an increase l
25 in the numerical coefficient associated.with the linear I !
I
. 13 1 relation between risk and dose. BEER-5, which '.s expected 2 to be released early next year, wi]1 include this revision.
3 Prelintinary estimates basen on our staf f's understanding of 4 what the 'tta is talling people is that that increase 5 would not be 1 order of magnitude increase but perhaps 6 of an order moutor of two.
7 CHAIRMAN ZECH: Before you go in on that slide, I 8 know there has been discussion for many years on this linear 9 relationship issue. In the extrapolation, as I understand it to that you are discussing here and in your paper, it would imply 11 some effect at low doses. I guess my questien would be what 12 is a technical basis for associating the like!thood of an 13 individual getting cancer at these low radiation doses? Has 14 there been any change in the thinking in the scientific 15 c7mmunity in this regard?
16 MR. MORDT*: I am not aware of changes. I have 17 discussed the issue of what technical principle is at play 18 here. The way I understand it is that the basic effect that 19 may cause the cancer to occur is the impact of radiation on a
- 3) DNA moleculc, If the dose rates tre very low, there is the 21 possibility that repair can take place in the molecule but Z2 the repair process is not thought to be 100 percent in the
%) sense tha*. 011 molecules will not be expected to be repaired.
24 In other words, there is a re-combinrtion of the bonds that 25 were broken by the radiation and that process'is not complete.
2
. le 1 So, from that basis, it has been theorized that 2 oven at very low doses you might not be able to exclude the 3 possibill'ty that cancer could occur. I think, you know, this 4 is a ver/ technical subject and there are others who could 6 describe it to you for better than I but that is my 6 understanding of the basis today for thinking that the linear 7 non-threshold hypothesis is --
8 MR. STELLO: Well, let me add I think a couple of 9 points to it because I have been asking that very question to of scientists and I think the impression I got from them is, 11 that they don't believe that these low doses are in fact 12 harmful. But the data that you have to get, the scientific 13 data, was one of the reasons I think in the BEER-3 report 14 ' they concluded that they did not have the evidence to show 15 it was harmful or not harmful because of the amount of ul information.
17 But some of the studies provide some insight to j un that. I remember reading of one -- I believe it was in China I
19 -- where they had about 150,000 people in a controlled 20 population, 70,000 at one dose level, the natural background, a
21 and about some number on tSe order of 70,000 at another.
i 22 There were, as I recall. 'ut one and a half or two times 23 gree background in ont ,t. , ..cion versus the other and 24 thei s no health offects. You see some of the same things 2 in the United States when you go out in the west at the higher i
15 1 elevations where the background doses are 100 millirem or
(
2 greater and you look at the health ef fects. In fact, I think 3 in.those cases the incidence of cancer is even lower but then 4 there are arguments that there could be other factors which 6 would in f act have contributed to this.
6 The point is when you try to go to the actual data 7 to be abla to glean from data to conclude that these low 8 levels, prove they are not harmful, you have the problem of 9 Etatistical data. But based on what we have seen from
~
10 sc.ience and what I understand the scientists have been telling !
- . 11 me, there is a growing concensus that they are not. But it 12 is subject to so much debate that we have just decided in
,, 13 fact to avoid it. There seems to be concensus that, to the 14 ' extent you want to use the word conservative, it is 15 conservative then just to use the extrapolation of the linear l
16 hypothesis that we have been using. -
17 That does not mean, in my view, that that is
, 18 conservative necessarily from a society point of view because !
l
- 19 3 0u are definitely adding a burden, a ?ost, that if society i 20 did it some other way, you could spend that money for some l 21 other purpose. This is one of the big, major issues of 1 .
I 22 debate; are these low doses really harmful? Here is where l
i 23 we hope we will be able to get some of the scientists around l
i j 24 the world to speak to this point.
i 2 CHAIRMAN ZEC11: All right. Well, maybe the
- 16 i following speakers this morning can also talk to this a little 2 bit. I am sure you will be dic.assing it at the 3 international workshop too.
4 MR. STELLO: Yes.
5 CilAIRMAM ZECli: But it has, as we all know, been a 6 subject of long debate and there are two schools of. thought 7 on the subject. But if there is any new thinking or any new 8 concensus or an'jthing like that, I thini it would be important g to the C3mmission to become aware of that.
10 MR. STELLO: Yes.
11 CllAIRMAN ZECil: Because we do know and we do have 12 scientific data for the higher lovels, as we know, and we 13 have reasonably good analysis of the higher levels of dcses 14 but we do not, as far as I know, have at the very low 12vols 15 and that is why we talk about -strapolation and scientific 16 analysis and so forth.
17 So, if there is any more definitive conclusion in 18 that area, I think the Commission would be very interested in 19 learning about that in your forthcoming discussions with the N international community and other experts.
21 Now, let's proceed.
22 MR. MORRIS: Going on to page seven of the 23 handout --
24 (Slide.)
t 25 MR. MORRIS: -- I just wanted to come back to this I
e
. 17 1 issue that the Commission raised in its staff requirements 2 memorandum. Thc' is the Commission directed the rtaff to i
3 dism po.;tcy str.ement an approach for implementing 4 the p .cw regulatory concern dose levels where 5 multiple usur . or licensed activities might be involved.
6 This has been one of the major issues that we grappled with l
7 as I mentioned before. There is a range of views on this 8 issue within the staff. I just wanted to highlight it again. !
9 I will be coming back to it later when we talk about these 10 dose limits and explain how we have gained confidence that 11 we can deal with this issue.
12 On page eight of the handout --
13 (Slide.)
(
14 MR. MORRIS: --
I mention one of the two ways that 15 the staff envisions that an exemption decision can be made.
16 That is the decision would be made on the basis of costs 17 benefit analysis where the costs and. technical feasibility of 18 measures v.hich could be trien to reduce doses are weighed [
19 against the risk reduction that would be achieved. That's 20 where the use of this $1,000 per person rem dose aversion 21 factor comes into play in the Conmission's decision making as 22 used in the application of the backlook (phonetic) rule and f
23 other decisions like that. The ALARA principle traditionally 24 has been' based on this kind of thinking. [
\
25 We also have provided another way to get at ALARA l
_ws,---r,,ne- -m-~m,,,w-em - - - ,-
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18 1 and that is indicated on the next page.
'(
2 (Slide.) ,
3 MR. MORRIS: The second basis-for decisions on 4 exemptions is that when the risk from the practice or source 5 is sufficiently small that there would be no need to require 6 risk to be reduced further, then an exemption should be, 7 granted. In other words, without cost benefit analyses of 8 feasible dose reduction measures. In other words, it would 9 be a declaration that you had reached a point of sufficiently to low risk that it is below regulatory concern.
11 The staff identified two risk parameters which can 12 be used to define the conditions for which this below 13 regulatory concern condition can be met and for which cost s
14 ~ benefit analysis can be waived. These are the annual 15 individual dose and the annual collective dose.
16 (Slide.)
17 MR. MORRIS: So, if you look on page ten of the is handout, we identify that we propose in the policy statement 19 that these values, these criteria, are ten millirem for an 20 individual and 100-person rem for the societal risk level.
21 We believe that to many these levels would be considered ,
22 ALARA and below regulatory concern.
23 So, if a practice is judged to be justified -- that 24 is it has a societal benefit -- and can be demonstrated to 1
26 meet these criteria,. then the granting of,an exemption under
. 19 9
1 the policy would be highly likely. Ilowever , it is emphasized
(
2 in the policy statement that failure to meet th'ese criteria 3 'fould not result in the exemption being rejected. In such a 4 case, ALARA could be demonstrated through cost benefit 5 analysis.
6 If we back up and look at slide number one that is 7 in the handout --
8 (Slide.)
9 MR. MORRIS: That is on the screen there now. It to is about four slides f rom the back of the package that we 11 handed you. I have indicated the risk methods of some of the 12 doses that could be envisioned. In particular, the ten l 13 millirem level for an individual dose is indicated here as 14 representing an increase -- this.is an incremental dose --
15 received from a practico exempted under this policy. That 16 would involve an increase in risk of two times ten to the 17 minus six per year of dying of cancer. This is one-tenth of 18 a percent of the cancer risk from all of the causes.
19 I think you will recognize that this is the samo 20 as the quantitative risk objective for reactor operation 21 adopted in the NRC's safety goal policy.
22 Using this same table maybe you can see, if you look 23 in this table -- I didn't put it down here but it is in the 24 Commission paper that the risk' conversion factor is two times 25 ten to the minus four. You can use that number' and remember
- - ~ . . ,
. 20 t that the other criterion we are using, the 100-person rem
('
i 2 collective dose which is the summation of all the individual 3 doses incurred because of the practice, that really amounts 4 to a very small annual risk to all individuals summed together 5 per year of the practice that would be exempted under this
- 6 policy automatically without cost benefit analysis. l 7 Another way to look at this 100-person rem number s . would be that if the practice persisted for 50 years, that ,
9 that would amount to one additional cancer fate.li+ in 50 10 years of the practice. That just gives me a perspective on 11 what kind of risk that we are talking about'. But, remember, ;
12 that is merely a criterion such that it tells you when you 13 must or must not do further cost benefit analysis.
-l ( ~
. 14 Let's go back to page ten of the handout. +
f 15 (Slide.)
16 MR. MORRIS: I just want to mention that these 1 17 criteria pertain to a single practice. They do not pertain i
j 18 to a collection of practices. It is the notion that you may ;
i :
! 19 have individuals exposed to more than one exempted or licensed l 1 !
! 20 practice that raises the question of whether or not you might !
21 be approaching that 100-millirem limit.
ZI Cl! AIRMAN ZECH: Before you go on, I was trying to .
23 do scme arithmetic on wnat you are telling us when you say 24 one in 50 years at the 100-person rem annual dose. If I I( i calculated correctly, assuming that there are 250,000 deaths 25 ri l
,--c- - - -~,e r, w w -,e +-e s. ,mm mn,,,emm--- _ wwm n arme p -. e , wm w w mw re g ym n,pn-e,w_. _ _ _ _ _ --, w - :- --
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1 per year due to cancer in the United States -- and I think i e
(
2 that'is a. low number, that'it could be higher than that.
3 MR. MORRIS: I think it is 500,000.
4 CHAIRMAN ZECH: Okay. Well, just say it's 6 250,000. . That's what I used. But say it's 500,000 or F
6 250,000, somewhere in that ballpark, one in 50 years,then ;
i 7 comes out to be between 12,000,000, 12.5 million, and ;
8 25,000,000, depending on whether you use 250,000 or 500,000, g between 12.5 sand 25,000,000 deaths then due.to cancer that t
10 we would expect in a total of 50 years.
11 MR. MORRIS: Yes, that'n what it calculates.
12 CHAIRMAN ZECH: So, what *tou are saying is that we r
( 13 would have one additional or one in addition - /-
14 MR. MORRIS: That's what this number amounts to. I
, i
~
16 . CHAIRMAN ZECH: --
to the 12.5 to 25,000,000 that i 16 night be expected; is that right?
17 ' MR. MORRIS: Well, that's --
18 CHAIRMAN ZECH: So, it is a pretty small number. l l
19 That's what I was trying to figure. Would you agree with M that? That is what you are sayirig.
f 1
l 21 MR. MORRIS: Yes.
7 22 MR. STELLO: That's why it's so difficult to get the i
23 data to how what happens for these very small numbers 24 because these numbers are well within the variation you have 25 in background doses.
b
, 22 1 CHAIRMAN ZECH: But what I was trying to figure 2 out, frankly, you know, is something that the general public 3 can understand is important I think, and when you tell me 4 ten millirem, I have got an understanding what that means 5 but lots of people really doi't. Ten millirem, it's just a 6 number. It's an absolute r. amber. But what does it relate to?
7 So, I was trying to say, well, why do this collective thing?
8 The collective dose, at least in my judgment, would tell me 9 that over a 50-year period when we would expect 12 to 10 25,000,000 deaths due to cancer in the United States, that 11 this below regulatory concern would mean perhaps one more 12 than that number.
13 So, it's a very small number; is that correct?
14 MR. MOORIS: Yes.
15 MR. STELLO: Yes.
- 16. CHAIRMAN ZECH: Were my mathmatics correct?
17 MR. MORRIS: That's close, yes.
18 CHAIRMAN ZECll: Al1 right.
19 COMMISSIONER CARR: I saw a quote from the cancer M Society this morning. Their estimate was 494,000 people this 21 year will die of car cer in the United States. If you look to 22 put that in a one-year perspective, if we went to say the 2 10,000-person rom, on top of that 494,000, you would see two 24 more people in this year.
2 CllAIRMAN ZECit: That's if you used what, the
y
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. 23 1 l'O , 0 0 0 --
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\- 2 COMMISSIONER CARR: Well, just put it in the one !
3 year. The 10,000 number says two in one year. !
4 CHAIRMAN ZECH: Right. !
6 COMMISSIONER CARR: So, you would try to find those 6 two guys in those 494,000 others.
7 CilAIRMAN ZECll: Well, that's what.they are saying.
a They are not using 10,000. They are using 100. :
9 MR. MORRIS: Yes.
U 10 COMMIS' . ON".R CARR : Well, but I was just trying to 11 make the point to do it in an annual year.
12 CHAIRMAN ZECH: An annual year, fine.
(, 13 COMMISSIONER CARR: You would see two more people.
14 CHAIRMAN ZECH: Sure, I see. Okay, fine, I 16 understand. Anyway, it's a small number and that's what you 16 are saying too.
17 COMMISSIONER CARR: Yes, it's the same thing you L
! 18 are saying. i i
19 CilAIRMAN ZECII: I think I'm trying to say the same ,
20 thing. I just used it for 50 years and you used it for one 21 year.
, 22 COMMISSIONER CARR: Yes.
2 L
23 Cl! AIRMAN ZEC'H: The point is, to me, the value of
[
4 24 it is not so much the number itself but the point I think you 1t 2 are trying to make is it's a very, very small number. f i :
.. 24 1 COMMISSIONER CARR: Yes.
r- I
'- 2 CHAIRMAN ZECH: That's what we are interested in, !
3 making sure that it is a very small number; is-that correct? ,
4 MR. STELLO: It is indeed. Perhaps in terms of i'
5 getting a perspective, it might be easier for the public to 6 understand the recent article that talked about radon 7 exposures, naturally occurring radioactivity in homes. The
- a radiation levels that they are talking about are in fact one 9 to two orders of magnitude beyond what we are talking about to - here. ,
I 11 Do you remember -- someone help me -- I think it 12 was a couple of years ago when the average background ;
J
( 13 exposure for individuals was in fact raised about 150 to 200 14 millirem.
15 MR. LAHS: From 100 up to 300.
16 MR. STELLO: So, it's a 200 millirem increase I
11 average in naturally occurring background radiation. There a
18 are levels in the country where the radon levels have been 19 measured and I think they have exceeded 1,000 millirem in
- 2) background levels in the home. So, you can get a fairly i
21 reasonable feel for the relative insignificance of this ,
t, ,
i 22 number conpared to something that there has been a great deal 23 of interest recently in terms of radon levels.
j ,
24 CllAIRMAN ZECll: Now, these numbers we are talking j
("
26 about this morning do.not include radon. .
, 25 1 MR. STELLO: They do not include radon. Radon is p-2 not a radioactive substance for which this agencp is 3 responsible for regulation.
4 Cl! AIRMAN ZECH: But what you are saying I guess in 6 essence is that the deaths from radon as far as we know now 6 would be considerably higher than the deaths that we are 7 talking about from radiation products. i 8 MR. STELLO: If someone would help me, I think as-g I recall the number in the newspaper wac --
y) MR. LAHS: 20,000.
11 MR. STELLO: -- 20,000.
12 CHAIRMAN ZECHt 20,000 per year --
( 13 MR. STELLO: Yes, per year.
14 CllAIRMAN ZECil: -- annual deaths in the United States ,
to MR. STELLO: Yes.
16 Cl! AIRMAN ZECil: And, what you are talking about --
\ .
I 17 MR. STELLO: Using the same techniques we used 18 which, I might add, there are many who questioned whether le those numbers are or are not correct too.
20 CilAIRMAN ZECil All right. Let's proceed.
21 MR. MORRIS: One point to remember there is that 22 that is the increment per practico, the definition that might 23 be involved in granting multiple exemptions under this. So, 24 I just wanted to remind you of that.
26 Cl! AIRMAN ZECll: All right.
l
. 26 1 MR. MORRIS: And, maybe ut this time, I think since I
2 we are at this point, it would be a good idea to look at 3 backup slide two for a minute. Again, that's in the backup 4 part of the handout.
5 (Slide.)
6 MR. MORRIS: I jtst might make a point now that in 7 tha ACNW letter that we received yesterday, there were 8 several points that they made. We think we can accommodate 9 most of those. They talked about the use of international 10 units, the definition of effective dose equivalent, 11 clarification of this concept of justification and 12 clarificatian of the linear non-threshold hypothesis that we 13 are using. But the major point tne letter nakes and one that 14 we are not yet ready to accept -- I wanted to call it to your 15 attention for that reason -- is that they believe the ten 16 millirem and 100-person rem criteria should be treated as 17 limits for each exempted practice and, in fact, that 18 exemptions should not be granted, as I understand their 19 letter, should not be granted under the policy if either one 20 of these criteria has been exceeded.
21 And, if you just look at this figure, we have drawn 22 the region of risk below ten millire:n and below 100-pet 3on 23 rem as the region where we believe it is simply appropriate 24 to not do cost benefit analysis but that does not preclude 25 in our minds that the Commission would not grant exemptions
9 27 .
1 for other cases outside that region of BRC risks. You could
/'
2 make the decision on other bases. It is an issue that you 3 will see, you know, if you peruse that letter and I just 4 wanted to call it to your attelition now.
5- Let's see if there is any other point that would be 6 made by this. We have indicated on here the regulatory dose 7 limit. So, in this figure, you could envision that you might 8 be looking at more than one exemption granted, and it is the 9 issue of how far up towards 100-person rem that you might get 10 from multiple exemptions that we will turn to in just one more 11 minuto now.
12 Let'. go back to page 11 of the handout.
13 (Slide.)
14 MR. MORRIS: The staff has recommended that the 15 proposed. policy state clearly that certain practices would 16 be excluded as candidates for exemptions. These would 17 involve practices in which radioactivity has been introduced 18 into toys or where radioactivity would be applied to or 19 ingested or inhaled by human beings. These practices have M not been considered to be justified in the past.
21 lloweve r , there was heretofore not a clear statement 22 from the Commission on these issues. We holieve at this time M that the Commission should make a clear statement of its 24 policy regarding this.
25 Again, on page 12 of the handout --
6
. 28 1 (Slide.)
'f 2 MR. MORRIS: -- this is another way of saying what 3 we mean by justification. We believe that'the release of 4 radioactivity where there are clear economical alternatives 5 or where there are no unique benefits from the use of 6 radioactivity should not be considered to be exempt under 7 this policy.
8 Let's go on to page 13 now.
9 (Slide.)
10 MR. MORRIS: I want to summarize some of the 11 provisions that are in the policy that limit the potential 12 that there might be individuals who could be exposed to
, 13 multiple sources of radiation exempted under the policy or 14 licensed by the NRC which could approach 100-person rom.
15 COMMISSIONER ROGERS: Excuse me a minute.
16 MR. MORRIS: Yes.
17 COMMISSIONER ROGERS: I want to just ask a question 18 on this to see what your thinking is on these items on page 19 12.
20 (Slide. )
21 COMMISSIONER ROGERS: You are talki:.g about 22 excluding from the exemption category items which there are
%3 c' ear economical alternatives or no unique benefits but does 25 ; I that mean in your thinking that you would exclude them from
\
75 any consideration? In other words, that even though they
o- .
. 29 1 would be excluded from exemption, could they be permitted in
- p.g i, e 2 some way? Now, not falling under the' exempted category but 3 still be --
L 4 MR. MORRIS: Under some --
5 COMMISSIONER ROGERS: - permitted in some way.
6 Have you thought about that?
1 7 MR. MORRIS: I have not thought about that. I am !
8 not aware of cases where we have done such a thing.
9 MR. LAHS: I don't know of any. l 10 MR. MORRIS: The members of tha group that worked l 11 on this do not recollect any case where we have allowed that l 12 to happen. We principally were looking at an exemption
( 13 policy. So, I really have not got a firm answer as to what i
14 we would --
15 COMMISSIONER ROGERS: Well, these things sometimes 4
16 do turn up. ,
1 17 CHAIRMAN ZECH: Well, why don't you look into that.
13 MR. MORRIS: Yes.
19 CIIAIRMAN ZECll See if you see the appearance of
]
20 anything that didn' t follow through there.
21 MR. MORRIS: Okay.
.i i~
22 MR. STELLO: 'I think that maybe -- I don't i 23 understand the question well enough -- but there are clearly
- 24 cases where there have been applications to use radioactive i
, t 26 material where we have rejected the application, period, f i !
4
- . _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ - , . _ _ _ . _ _ . _ _ _ _ . _ _ _ . _ ~
. . 30 I without this policy in place. We have just said in our 2 judgment that is not a correct use of the application and we 3 rejectcd it. Now, any licensee is entitled pursuant to our 4 regulations to follow the process of appeal and go through 5 the agency to have his, if you will, day in court.
6 But we would not only pursuant to this policy but 7 continue to follow the past practice if we felt there was 8 something that just ought not to be an area where radioactive 9 material ought to be used and that was our judgement. We 10 would continue to make the judgment that that application 11 ought not be allowed and permittsd.
12 COMMISSIONER ROGERS: Well, I do..'t think we should 13 prolong this discussion on this particular point but my 14 concern ultimately will come back to this question of 15 justification a!.d not that the justificatic,n is not an 16 important coneideration but who is going to make that 17 ' decision. It could overlap into this area. So, I would 18 like to return to that at some point when it is appropriate.
19 I don't want to derail the presentation to attack that but I N think at some point I want to hear more about how one 71 envisions this question of justification being decided.
22 MR. STELLO: Okay. Well, let ne comment then I 23 think that would be an interesting subject the next time we 24 have an application we are going to reject, that we will come 25 to the Commission and explain what we do, fQr example, and
r .
. 31 1 why.
2 COMMISSIONER ROGERS: Well, it's somethihg that we 3 had to grapple with when we considered the gemstone issue.
4 MR. MORRIS: The gemstone issue, that is correct.
5 COMMISSIONER ROGERS: I am not sure that we really 6 settled all questions with respect to how this would be 7 decided.
8 MR. STELLO: No.
9 COMMISSIONER ROGERS: So, I think it is a very 10 important issue for us to approach but I think we can set it 11 aside for the moment. But I would want it on the list of 12 things which are under active consideration for explanation
/ 13 to the Commission as to how that justification question is 14 going to be decided.
15 MR. STELLO: Okay. And, I am suggesting that the 16 next time we have an application we are rejecting, we will 47 Fring it to the Commission and explain that parti.ular case 18 and then have a more generic discussion of how we do that 19 because I think it is outside this policy.
20 COMMISSIONER ROGERS: Well, just as a general 21 comment, I always like to make decisions in the absence of a 22 particular case that has to be decided.
23 MR. STELLO: Okay.
24 COMMISSIONER CARR: Is the justification issue i
25 going to be discussed at the workshop coming up?
_ _ _ - ,.n,.
aww~
1
. 32 1 MR. MORRIS: Yes.
2 MR. LAHS: Yes.
3 CHAIRMAN ZECH: All right. Let's proceed.
4 MR. MORRIS: Going on to page 13 of the handout 5 now --
6 (Slide.)
7 MR. MORRIS: -- and talking about now those 8 provisions that we believe limit the potential to impact 9 people through multiple exposure. First, there are the ten 10 millirem ar.d 100-person rem dose criteria we proposed. With 11 regard to the ten millirem individual dose, it should be 12 emphasized that this is the maximum dose reasonably expected 13 to be received by an individual due to the given practice.
14 So, only under unusual circumstances would the majority of 15 the people exposed to that practice be up near the ten 16 millirem limit.
17 However, if one were to hypothesiv.e such a 18 situation, the 100-person rem population dose critorion 19 limits the number of individuals who could be exposed at the 20 ten millirem level or near to it to no more than 10,000 21 people. So, what we are doing is we are saying that if you 22 are looking at potential for people in the population at 23 large to be exposed to multiple sources, these two criteria 2t reduce that potential somewhat.
(
25 Also, the policy makes clear -- we have just
6 1
. 33 .
1 discussed this issue of justification -- that only 2 justified practices will be allowed. This principle would 3 assure that we are not facing a situation where unnecessary 4 exposures are being encountered. Therefore, that is going to 5 also give assurance that you won't have many people that 6 would possibly be near the 100-millirem level.
7 Going on to page 14 and continuing thia thought --
8 (Slide.)
9 MR. MORRIS: --
there is a key point in the policy to that as the policy is being implemented there would be an 11 assessment of this potential for cumulative doses to various 12 key members of the exposed population, that there would be a
- 13 potential that they would get unacceptably high doses, those 14 approaching 100-millirem. Each time we make an exemption 15 decision,.we will look at that population, choosing the key 16 members who would be limiting in that regard that they might 17 be rocciving doses f rom other practices. And, if we find 18 that we believe there is a potential that that could happen, 19 then we are going to require that further analysis be 20 necessary before an exemption could be granted.
21 Going on now to page 15 of the handout --
22 (Slide.)
23 MR. MORRIS: -- we would point out also that in 24 the policy statement, in the very first paragraph I believe, M we talk about the concept of practice and the concept of
. 34 1 fractionation of practice. The policy says that r
2 fractionation of practice will not be allowed. That is where 3 there are similar activities, similar kinds of releases that 4 could occur. They wouldn't be treated in an integrated way 5 so that you won' t have a proliferation of practices that 6 shoilld be actually integrated together in our thinking 7 process. And, by that, we believe that we will have 8 artificial situations that will break these practices up and 9 allow ten millirem and 100-person rem for each exempted to practice when that wouldn't be reasonable to do.
11 Finally, wo believe that as experience is gained 12 in this issue as policy is implemented, we will learn more
( 13 about what this potential is like. If there were a number of 14 new applications for consumer products to be exempted, for 15 instance, that would make us take a close look at whether 16 this policy was giving the kind of protection that we thought 17 was necessary. So, we will just use common sense and good 18 judgment as we go forth to imploraent the policy. If 19 something is determined to warrant a re-look, then we would N take that initiative and do that.
21 Now, one other point that we wanted to make was in r
22 the course of performing collective dose calculations which 23 would be done say for cost benefit analysis, the staff has 24 identified several methods that we would find reasonable in 25 order to truncate these doses.
- - 35 1 (Slide.)
2 MR. MORRIS: We included truncations in space --
3 that is at some large distance f rom the source so that the 4 doses clearly are going to be small and neglig!ble -- and 5 truncations in time so that after radioactive products have 6 decayed to a very low level, then the doses would be 7 negligible. We have also open in the policy the issue of a cutting off these collective dose calculations at low g individual doses which we believe might be considered
)
to negligibic by most people such as one-tenth of a millirem.
11 All of these provisions would simplify and reduce 12 the burden on those who are trying to do these sometimes c 13 sophisticated cost benefit analyses. We don't think they 14 should necessarily be so sophisticated when they are making 15 those simple judgments. So, this is moving in that ' direction 16 to send a clear signal that you do not have to go to infinite 17 lengths to determine what the collective dose is.
18 Finally, we open the possibility too of weighting 19 collective dose with different factors depending on what m range of individual dose the collective dose was roccived in.
21 So f ar the Commission in Appendix I 'sas indicated that $1,000 n per person rem is an acceptable weighting factor to convert 23 dose to cost so that you'can compare those with the cost of 24 reducing the doso. Now, this opens'up the possibility that 25 other ways to do that could be entertained. In fact, in this
l
. 36 1 body of ways to treat collective dose that I have just been
/
2 discu: sing, the staf f would recommend that a variety of 3 these concepts -- you know, that you could combine these 4 concepts to do what makes sense when you are calculating 5 collective dose.
6 I think just to end this up, I just wanted to 7 mention that we do have the plan to go to the international 8 workshop to discuss the diversity of international regulatory 9 views with other regulators.
10 (Slide.)
11 MR. MORRIS: There are commitments from regulators 12 from ten countries who would be joining us.
13 (Slide.)
14 MR. MORRIS: We would have the International 15 Commission on Radiation Protection, the Nuclear Energy Agency, 16 and the --
17 MR. LAHS: Community of European --
18 MR. MORRIS: -- Community of European --
19 MR. LAliS : What did we say before? We just looked 20 that up.
21 Cl! AIRMAN ZECH: Excuse me. Just one of you talk at 22 a time so the reporter can keep track of what --
M MR. MORRIS: I'm sorry. We will also have EPA, 24 DOE,' National Council on Radiation Protection, and the 25 Advisory Committee on Nuclear Waste attending, The workshop
. 37 1 will be held, as I mentioned, in October, and it will be held
(
' in Washington.
2 3 (Slide.)
4 MR. MORRIS: So, what we would be~ awaiting is the 5 Commission's guidance on what we would focus on in that 6 workshop.
7 MR. STELLO: Mr. Chairman, we are about finished.
8 In the paper we had suggested that perhaps the policy 9 statement subsequently would be changed and then issued for 10 public comment. I have been thinking more and more about it 11 and I cannot see any reason for delaying it. I think I am 12 satisfied it is in a form now where we could in fact issue 13 it for public comment.
14 CIIAIRFmN ZECH: Do you mean before the international 15 meeting? Is that what you are saying?
16 MR. SThbLO: Yes.
17 CHAIRMAP ZECII: All right.
18 MR. STELLO: So that we would have a generous 19 opportunity for public comment. I don't see any reason to N hold up doing that. The only risk is that we might want to 21 have public comment twice but that wouldn't concern me either.
22 I think it is important to try to generate to the extent we D can further comment and debate in this area. So, I would 24 urge to move out whatever the Commission feels that we
(. 2 addressed all of the questions that need to be addressed and
38 1 if we have to ask specific questions in a comment period, why c'
2 we could easily just add those to it and move on rather 3 crisply with getting the comments.
4 Cl! AIRMAN ZECH: Well, let me make sure I understand.
5 I thought the purpose of this meeting was to get the 6 Commission authority to go to the international conference 7 with at least the proposed strawman policy.
8 MR. STELLO: Yes.
9 CllAIRMAN ZECll: And, then after the conference, you 10 would come back to us with your slews and then we would go 11 out officially. Now you are saying that we would go out 12 ahead of time for public comment; is that right?
13 MR. STELLO: And, then come back to the Commission 14 after that public comment but then putting 4.t out one more 15 time.
16 CilAIRMAN ZECH: There would be a public comment 17 period twice.
l 18 MR. STELLO: Yes. I think in this case it might be l
l 19 wcrth it.
El CllAIRMAN ZECH: All right. Then are you making a 21 different proposal than we had before the meeting?
22 MR. STELLO: I am suggesting that the Commission 23 might want to consider that because of the interest in this 24 issue, that instead of trying to publish it once, do it twice.
(
2 Put it out right now and have the benefit of that comment
- 11
. 39 ,
1 process perhaps twice. I don't see any problem with that in 2 going in that direction. The Commission r.ay want to consider 3 that.
4 CIIAIRMAN ZECII: Does the General Counsel have any 6 comment?
6 MR. PARLER: There is no legal requirement, Mr.
7 Chairman, for policy statements to be put out for public 8 comment la any event, although that is in my judgment a good g practice to follow. The agency has followed it on a number ICf of occasions. I am at a loss myself from my perspective to 11 ;
see how putting the thing out for public comment prior to the 12 international workshop would be overall beneficial. .It might c 13 give the participants in the international workshop the idea 14 that some minds have been made up prior to the ext Sango of 15 information.and the exchange of views.
16 Also, it is my understanding that the workshop 17 perhaps may be limited to the participants from the variouc 18 organizations and countries. To put the policy stateinent out 19 for comment in advance of the workshop under those conditions
- 3) might unneces- , ., , mplicate the thing. Those are my 21 thoughts but thers e no legal problems.
I 22 CllAIRMAN ZECll: Right. Thank you very much. Do
%) you have any other comment on that, Mr. Stello?
24 MR. STELLO: No, sir.
M CilAIRMAN ZECil All right. I know we have two other
. s
. 40 1 speakers but perhaps before we ask them to come forward, I 2 will ask say fellow Commissioners if they have any comments or 3 questions that they would like to address to the staff.
4 Commissioner Roberts.
5 COMMISSIONER ROBERTS: No.
6 CHAIRMAN ZECH: Cc;missioner Carr.
7 COMMISSIONER CARR: No.
8 CHAIRMAN ZECH: Commissioner Rogers.
9 COMMISSIONER ROGERS: Well, just on this to justification. I don't expect an answer now but I think that 11 is something that I really would like the staft to dig into.
12 MR. STELLO: We will arrange to brief the 13 Commission separately on that issue.
14 COMMISSIONER ROGERS: All right. Thank you.
l 15 CHAIRMAN ZECH: All right. Thank you very much.
16 I guess the next speaker is either Doctor Taylor or 1:r. Lahs.
17 What order do we have them? Mr. Lahs.
18 MR. LAHS: No, I'm here with the staf f.
I 19 C11 AIRMAN ZECll: All right. Doctor Taylor t.nd Mr.
- 3) Tipton; is that correct?
21 MR. STELLO: Yes.
22 Cl! AIRMAN ZEC!l: All right.
23 (Pause.)
24 MR. ALEXANDER: I would like to intrn@tco the M doctor, please.
. 41 1 Cl! AIRMAN ZECil: All right, fine. Please do.
t 2 MR. ALEXANDER: Good morning. I am R. E.
3 Alexander, President of the IIcalth Physics Society. This 4 society has 6,400 members and is believed to encompass and 6 ', represent concensus scientific opinion in the field of 6 radiation protection and health offects. We believe that 7 concensus scientific opinion should have a more prominent 8 role in public health policy development and today we are 9 making our initial attempt in that direction.
10 The society is grateful to the Commission for 11 providing this opportunity. We have prepared a list of 12 criteria that we believe should be met by the BRC level 11 selected and this list ir available for your consideration.
14 With regard to the collective dose question, the NCRP has 15 stated,"There are no direct data that confinn that a 'few 16 random ionizations in tissue cause fatal cancers.
17 Irrespective of such scientific opinion, Laere has for many l 18 years been concern over extremely small radiation doses if I
they e.e received by extremely large numbers of peopic.
20 Considering current radiobiological and 21 epidemiological information, it is o' position that 22 public health po) y derived from such concerns is not 23 scientifically sound. Risk estimates made in this manner 24 must be described as speculative o; inadmissible. Even if I
25 such risks actually exist, they are imperceptible and too M
. . 42 1 small to be of regulatory concern, b
2 For these reasons, it is the position of the society 3 that the com:nission's generic BRC level should not be 4 accompanied by a collective dose rootriction. Such a 5 restriction could defeat the Commission's purpose with 6 respect to effluent control, low level radioactive waste 7 management, de-commissioning, and other practices involving 8 the exposure of large numbers of people.
9 Whether an agent carcinogenic at high exposures is to also dangerous at low levels may be unknown. If the risks 11 could be substantial, regulation or even prohibition may be 12 necessary. If the hypothesized risk is known to be small,
\
la costly regulations can be imprudent. Such is the case with 14 radiation doses as low as ten millirems per year. If doses 15 this low create a substantive public risk, we would have 16 evidence from high natural radiation areas where people 17 received doses on the order of 1,000 millirems per year. No 18 adverse effects have been found among these people.
19 However, if the Com;..Assion snould find it necessary 20 to establish a collective dose criterion, we recommend 21 acceptance of the NCRP advice to exclude from the dose i
22 calculation those people who receivu less than one millirem 23 per year. ;
24 The society spokesman today will be Doctor Lauriston
\
25 S ., Taylor who was our President in 1958. Doct9r Taylor was a
43 I co-founder of the ICRP and founder of the NCRP. He was the 2 first Chairman of the NCRP, a position in which he served 3 with distinction from 1929 until 1977 He has also served on 4 the ICRP and is now an emeritus member of both the ICRP and 5 NCRP. lie has essentially devoted a long and distinguished 6 career to the development of radiation protecticn 7 recommendations for public policy makers such as this :
8 Commission.
9 It is my honor and pleasure to introduce Doctor
. 10 Taylor at this time.
11 Cl! AIRMAN ZECll: Thank you very much. Doctor Taylor, 12 you are very welcome. Please proceed.
13 DOCTOR TAYLOR: Thank you. Speaking for the !!calth 14 Physics Society, I was asked to express two appreciations to 15 the Commission. The first of these was for the opportunity 16 of appearing before you to present evidence of our society's 17 concern and interest in what you are doing and in support for 18 what you are doing. f 19 The second expression of appreciation would be for N the Commission's support of one of its staft to become 21 President of the worlds largest radiation protection 22 organization, the !!calth Physics Society. We realize that N this makes a considerable drain from time to time on the 24 parent organization of these individuals but also we believe 25 that it not only helps the society and the country in general
O 44 1 but we think it also helps the parent body.
2 Since the meeting of the Nuclear Regulatory 3 Commissien today is attended by the public, I want tc make it 4 very clear what the term "health physics" means. It is a 5 word not well understood by the general public. At the outset e of the weapons program under the Manhattan District operations 7 in 1943, it was recognized that radiation safety and the a protection of people would require one of the major efforts 9 in their program. At the same time, they were afraid that if to the word radiation were to appear in any way in connection 11 with that program, it might give away the secret of what they 12 were working on which of course was the first atomic bomb.
13 To preserve the secrecy, they called the radiation protection
(
14 activities "health physics". It was a decoy name meaning 15 nothing that might be associated with radiation.
16 Unfortunately that same name has hung on and the 17 public most of the time does not know what the word "health 18 physics" means. What it means is radiation protection and 19 health physicists are radiation protectionists. That's what W lt'^ all about. ;
21 Now, in the radiation protection community, we have 22 been increasingly concerned about the complexity of our J .- radiation control measures, the drain from our professional 24 manpower and the heavy financial burdens that are restraining i
important applications of ionizing radiation in science, 25 ;
. 45 ,
1 medicine and industry.
2 For example, we are f acing a continuing shortage of 3 trained radiation protectionista in this country. The costs 4 of protection are no longer commensurate with the degree of 5 protection that is being provided with these high costs in 6 the low level region. The cost por unit improvement in 7 radiation protection increases enormously when we get down a into the very low dose range, especially the range which is 9 only a small fraction of the natural background at which wo 10 are exposed all the time.
11 I'm sure the NRC can develop some specific 12 information on this question and I have heard it discussed 13 already this morning their plans to do so and the' sound 14 sound. As ar example, we have heard something of the order 15 of 90 percent of the costs of the overall effort that is 16 expended on radiation protection is expended in the very low 17 dose range where the effects of radiation cannot be found 18 specifically by any means that we know of today. Why? Why l's all this?
i 20 Well, the statistical methods that we have today 21 and probably will always have are simply inadequate to deal 22 with the small size samplea that we have to work with. Also, 23 direct observation may come some time in the f ture but there 24 is nothing in sight. T. tere are some but extremely limited M data in the range of five to ten-rem acute exposure and five-lI
. 46 1 rem per year exposures extending over many years. We use i
2 what data there are available but we are still left with huge 3 gaps in our knowledge with little likelihood in' sight for 4 solving some of these openings or closing some of these 5 openings.
6 Now, the lack of information and data in the low 7 dose rar.ge -- I call an"thing below ten rems a low dose --
8 but anything lower than that has forced our main scientific g body such as the --
10 CllAIRMAN ZEC11: Anything below ten rems.
11 DOCTOR TAYLOP: Ten rems.
12 C!! AIRMAN ZECil: Anything below ten rems you call a 13 low dose.
14 DOCTOR TAYLOR: I call a low dose.
15 CliAIRMAN ZECil: Ten rems, what, per hour or per 16 year?
17 DOCTOR TAYLOR: Well, ten rems in a single shot, in 18 an acute exposure.
19 Cli AIRMAN ZECll: Over what period of time?
M DOCTOR TAYLOR: Ten rems in one minute or one day 21 or a week.
22 CllAIRMNi ZECll: A total of ten rems you are talking l
q 23 about.
24 DOCTOR TAYLOR: A total of ten rems, s
%5 C!! AIRMAN ZECll: Not in an hour or a year but just
. . 47 1
a total absolute number, ten rems.
2 DOCTOR TAYLOR: Well, a total in a short time. If 3 it is delivered in a long time, it can be a lot more than 4 that.
5 CllAIRMAN ZECit Well, that's my point.
6 DOCTOR TAYLOR: Oh, yes. Well, this is a ten-rem 7 single acute dose, a Cl! AIRMAN ZECll: All right.
9 DOCTOR TAYLOR: The reason that I name that figure, 10 which I won't support too heavily, is because we simply don't 11 have any decent data to work with below that level. Everything 12 from there on down involves a certain degree of speculation
{ 13 and assumptions.
14 Cl! AIRMAN ZECll: I understand. Thank you.
la DOCTOR TAYLOR: That's the reason for it.
1C Cl! AIRMAN ZECll You may proceed.
17 DOCTOR TAYLOR: This situation I was starting to 18 say has forced the main scientific bodies such as the NCRP
- 19 and ICRP to extrapolate the occurrence of effects from the
- 3) high dose region where we do know a lot about radiation 21 ef fects in terms of dose to the low dose region where we have 22 no information. This is ali extrapolation and a number of 23 assumptions. Simultcncously, we have to use compounded 24 assumptions, one assumption after another. Invariably, when 2 assumptions are made and you are thinking about a problem that I
i
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- . 48 1 covers maybe a range, it is almost always the case that the i
2 people who are making these assumptions veer in the direction 3 of conservatism and this is the vay it should be but it also 4 makes for a very severe and perhaps over-protection 5 requirements.
6 Big expenditures are made to ensure low doses in 7 the region where we can't find anything except in theory or 8 by involving assumptions. This big of. ort is known to the 9 public and it creates the impression that if it is designed 10 to meet some strange situation, it must be very dangerous.
11 Otherwise, all of this effort wculdn't be devoted to it.
12 They can't understand it. They don't know that the scientists 13 don't understand it. So, they think it is something about 14 which they should be alarmed.
15 Any action taken by the government in any trivial 16 matter or a matter of relatively low importance excites undue 17 perceptions on the part of the media and of the general public, 18 That's one of the problems we have to face in this particular 19 question.
- 3) Now, from the health physics side, we don't want to 21 pretend that we are trying to tell the Nuclear Regulatory 22 Commission very mucn or maybe anything that it doesn't already 23 know. I listened to the presentation this morning. I agree 24 with just aboilt every word that was said. Obvi'.usly you are s
2! understanding these things. .
49 1 We are aware of your preoccupation with the BRC 2 concept and that you are grappling with the problem. What we 3 do want you to know is that the Health Physics society of 4 radiation protectionists shares your concern and shares ysur 5 concern and shares your positive and promising ef forts to 6 control it.
7 I will mention a few further points as I go along 8 but these will be primarily for emphasis and to indicate that 9 our two organizations are thinking alike, yourselves and
, to ourselves. I will assume that you have had the opportunity 11 to read at least the first couple of pages of our letter of 12 September 8th. I hope that's a better assumption than we can
(
13 make about many of our technical matters.
14 We will not offer you any specific proposals for 15 a level of radiation exposure that should be below regulatory 13 concern. We do, however, offer you our help and cooperation 17 in solving this problem if you were co request it. The final 18 answer on the BRC problem can come only from you. By you, I 19 mean this organization. But because it is not primarily a M scientific or technical problem, however much it may be based 21 on scientific and technical data. Your kind of organization 22 is the only kind that is properly constituted to deal with 23 the question. The question is politic and can be solved only 24 by actions that are, and I quote, "prudent and sagacious in 25 devising and pursuing measures adopted to promote public
50 1 welfare", the kindness of Mr. Webster.
2 Personally, I find it compelling when considering 3 such a problem as below regulatory concern to examine the 4 common sense of the situation, together with the technology.
5 We know that radiation, among hundreds of other agents, cause 6 cancer. We know that one-third of us sitting in this room 7 today will have cancer at some point in our lives and that 8 half of those will die from cancer. But we have no direct 9 statistical evidence of cancer having been induced by 10 radiation exposures below maybe five rem in a single 11 exposu 1 -- I mentioned ten rema before but five rem is a 12 more common figure -- or one rem per year spread over many 13 years continually.
14 Now, it has been conservatively proposed that the i
15 upper limit of exposure of individuals in the public not 16 exceed one-tenth rem or 100-millirem in a year. To ensure 4
17 that this level of exposure is not exceeded, the protection 18 bodies are suggested a goal of one millirem per year as an 19 average dose to the whole population. This is a dose which M they describe as being of negligible risk or at a negligible 21 cisk level. One millirem a year. Now, why are we doing this 1
22 to ourselves? We cannot find any offect, so we theorize them.
23 We cannot measure the exposure, so we calculate them. But 24 each and every step in each process, there is a large number 25 of assumptions and choices of range and, as already noted, 1
. 51 .
1 they are almost always drawn in the direction of
~
2 conservatism. '
3 In the general goals, the Regulatory Commission has 4 an overall safety goal of 25-millirem for its general 5 coverage. I won't go into detail as to how that is 6 distributed. To achieve this at the prasent time, the NRC 7 must regulate every radiation matter coming within their a jurisdiction all the way down to =cro exposure but, fortunately, '
9 the law does not require the NRC to regulate the exposures 10 *from natural background radiation which as a matter of fact 11 outweigh the ones that man is making.
12 In establishing a radiation control system, there l
13 are two factors. One 12 the matter of individual dcscs and 14 the second is the matter of collective doses for the whole 15 population. That istheaveragedosetoindividualsmultipliep 16 by the numboc of individuals. This can be applied where you can 1 17 measure doses and you can measure the number of people that 18 are exposed. These objectives can be accomplished with a 19 modest effoct in the upper dose region but in the low dose 20 region it become increasingly difficult, increasingly costly 21 and doereasingly impurtant in the regions that are less than 22 the 25-millirem level that you regarded as your overall goal.
23 Now, a perceived stumbling block in instituting a
]
24 BRC plan has been the incorporation of the collective dose 25 requirement. !!oweve r , the NCRP recommends that the requirement
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, 52 1
for a collective dose evaluation be explicitly elimin .ed 2 from any nced or consideration in the region that is 3 described below regulatory concern. They happen to have 4 suggested what might be used as a BRC as one millirem a year 5 a I mentioned.
6 Thus, if the Regulatory Commission were to choose
- a number higher than one millirem per year as their level, a that could be below regulatory concern and the same g exclusion of the requirement for collective dose consideration to would apply.
11 I might state parenthetically when I said that the 1: NCRP made this recommendation about a BRC, actually their 13 terminology was negligible individual risk level but that is 14 the same as BRL. I'm getting mixed up in my acronyms.
15 CilAIRMAN ZECll BRC.
16 DOCTOR TAYLOR: BRC. The NCRP's suggestion would
, 17 apply to the whole population for all sources of radiation, is whereas the DRC would apply to those sources of radiation gg subject to regulation by the Commission. To be sure of that 20 last statement, which I think is very critical, I checked 21 them both with the members of the NCRP and ICRP, a member of 22 the ICRP and Chairman of the Committee I of the NCRP, and 23 they have verifica those statements that I just made as being 24 in accordance with their understanding.
25 The ICRP does not like the whole restriction
. . 53 1 question about collective annual effective dose equivalent 2 and so far has not mentioned it at all. It is a question 3 that has been under same discussion by them but apparently 4 it is not coming to any visible conclusion at the moment.
6 Thus, I do not see any restriction on the NRC in 6 choosing a DRC level that will cause conflict with either of 7 the above radiation protection bodies. Thank you, sir.
8 Cl! AIRMAN ZECH: Thank you very much, Doctor Taylor.
9 Why don't we hear from Mr. Tipton nex* and then we will to entertain questions from my colleagues.
11 MR. TIPTON: Good morning.
12 Cl! AIRMAN ZECll Mr. Tipton, you may proceed.
13 MR. TIPTON: Good morning. I am Tom Tipton, 14 Director of the operations, Management and Support Services M Division of the Nuclear Management and Resources Council, 16 NUMARC. Byron Lee and Joe Colvin are on travel and send 17 their regrets that they could not be here today. I would 18 like to thank the Commission for the opportunity to appear 19 before you at this meeting to present a statement on behalf of MUMARC with input from representatives of Edison Electric f
21 Institute, the Electric Power Research Institute, Utility 22 Nuclear Waste Management Group and the U. S. Council for 23 Energy Awareness.
24 With me today are the followin'g industry s
25 representatives and they are to your right: Mary Birch,
54 1 Technical Systems Manager, Radwaste Engineering, from Duke 2 Power Company, and Chair of EPRI's BRC Owners Group Technical 3 Advisory Committee; Lynne Fairobent, NUMARC Project Manager; 4 Pat Robinson, Director of EPRT.'s Below Regulate ry Concern 5 Owners Group; Steve Kraft, Director of UNWMG; and Dixon iloyle ,
6 Project Manager, Nuclear Fuel Cycle of the USCEA. These 7 individuals are directly responsible for the p2ojects I will s be discussing here this r orning.
9 The ni. clear industry has supported and continues to 10 support the NRC's efforts to designate levels of radiation 11 that are below regulatory concern. Since the generic BRC 12 issue involves several industry organizations and addresses 13 a gene':.tc isaue, NUMARC is responsible for coordinating these 4
14 industry activities. To accomplish that, we established a 15 BRC Ad floc Advisory Committee, which has representation from to all industry groups addressing different aspects of the issue.
17 A draft industry program plan is being prepared and will be j 18 distributed in the near future. It describes the range and 19 scope of industry activities relating to the BRC issue and the ;
I 20 key milestone dates. We plan to make it available to your ,
21 staff so that yea will be fully aware of the industry's 22 programs.
4 23 llowever, we think it is important to briefly 24 highlight today some of the industry activities already 2 completed and those in progress that address this, issue and
0 *
. 55 1 then mention some important points for your future 2 consideration. Again, we appreciate you allowing us this 3 opportunity.
4 There have been several detailed industry studies 5 addressing the issue of DRC dating back to the late 1970's.
6 Some examples are identified in Attachment A to my 7 presentation. I want to emphasize that these are not all of a the studies but only a representative sample of what the 9 industry has done.
. 10 In July of 1984, EEI and UNWMG filed a petition 11 for rulemaking with the NRC regarding the disposal of 12 radioactively contaminated waste oil from nuclear power 13 plants with levels of radiation that should be classified as 14 being below regulatory concern. We are pleased that NRC has I
15 published for comment in the August 29, 1988 Pederal Pegister 18 a proposed amendment to its regulations to permit the on-site 17 incineration of slightly contaminated waste oils generated 18 at nuclear power plants. The nuclear industry will be 19 submitting comments on the proposed rulemaking.
20 The industry has also been involved in related i I
21 activities. Extensive comments on the proposed revisions to i 22 10 CPR Part 20 were provided in October of 1986 by the former Z3 Atomic Industrial Forum and EEI. Detailed comments on the 24 NRC's BRC recommendations were included'. The industry also t$ commented extensively on the NRC's advance notice of proposed
1 56 g rulemaking on radioactive waste below regulatory concern 2 published in the December 2nd, 1986 Pederal Regioter. These 3
comments included a strong endorsement of the Commission's 4
proposal to develop BRC regulations.
8 NRC published in the August 29th, 1986 Federal 6 Register a policy statement and staff implementation plan 7 regarding expeditious handling of petitions for rulemaking a to exempt specific radioactive waste streams from disposal in 9 a licensed low level waste disposal facility. This policy go statenant provided the long sought opportunity for the 11 nuclear industry to pursue the exemption of wastes with very i
12 low activity levels from NRC regulations.
13 In response to the August 1986 policy statement, 14 EPRI and UNW!!G initiated a joint program in early 1987 to 15 develop a petition for rulemaking to e:.cmpt very low level to kaste produced at nuclear power plants. EPRI is providing 17 the research and the technical data to support the petition, i
gg and UNWMG is providing program support, including legal >
gg suppcrt and draf ting the petition. The EPRI research effort 20 is nearly complete, It alone represents an expenditure of 21 approximately 2.2 million dollars. The present target is to 22 submit the petition by the end of this calendar year.
23 The petition will propose that the regulations 24 [ allow the disposal of slightly contaminated wastes in on-site 25 landfills, off-site sanitary landfills, and on-site and off-
57 .
I site incinerators. It will fully comply with the detailed 2 criteria set forth in the Commission's August 1986 policy 3 statement and the staff's implementation plan, and will 4 therefore qualify for expedited processing.
5 Now, I would like to briefly summarize some 6 important points for your consideration during future 7 discussions on the issue.
8 First, it is important that any NRC action 9 identifying a level of radiation risk or dose below which 10 government regulation would be limited or unwarranted be t 11 consistent with, and not negate in any way, the August 1986 12 policy statement. We need to preserve the options it provides 13 as well as the investment the industry has made in preparing ,
i 14 the petition.
15 6econd, we feel that a process shculd be established 16 to determine appropriate DRC levels and I want to emphasize 17 from the industry's point of view, we feel that the BRC 18 program is a prneess, including the perfon. 'nce at a cost / l l
19 benefit analysis 'or higher BRC exempted dose levels. Less A) rigorous analyses would be required for lower dose values, i
21 We generally support an appcoach similar to that presented 22 by the staff at the September 13th, 1988 meeting of the 23 Advisory Committee on Nuclear Waste. I want to interject 24 with a very preliminary review of the ACNW's letter of i
25 September the 15th. We don't support it because it appears P
P i
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. 58 1 to eliminate the process that we think BRC represents and 2 ic just creates limits. Prior induatry comments on the issue 3 support individual dosos in the range of ten to 20'-millirem 4 per year as the generic BRC, 5 Third, since protection of the individual assures 6 adequate protection of the overall population, the 7 esta ,11sk 2nc of an annual collective dose person-rem 8 standard for BRC is not appropriate.
9 Finally, it is our understanding that the staff 10 currently intends to make BRC standards a matter of 11 corpatibility for agreement state regulatory programs. In 12 order to realize the full benefits from the Commission's BRC
,t 13 initiatives, it is crucial that BRC standards be adopted by 14 agreement states identical with federal requirements, in a
'S manner similar to the Commission's other radiation protection 16 standards.
17 In conclusion, the industry strongly supports 18 initiatives to address the BRC issue; as reflected 1. the 19 work that has boon initiated over the past decado, rurther, M the industry believes that the development of BRC is important 21 to the conduct of good radiation protection programs while at 22 the same time making it possible to minimize the expenditure 23 of resources on matters that pose trivial levels of risk.
24 We support the need to address the generic BRC ,
25 issue in a timely manner and encourage the continued exchange l.
59 1 of information as it becomes availabic, i
2 Establishing regulatory cut-off values would 3 assure that our limited resources are being used most 4 effectively in protecting public health.
5 In addition, we also support Vic Stello's 6 recommendation that the draft policy statement be issued for 7 public comment as soon as possible. Thank you very much.
8 CilAIRMAN ZECll: Thank you very much. Any questions 9 from my fellow Commisaloners? Commissioner Roberts. ,
10 COMMISSIONER ROBERTS: No.
11 CllAIRMAN ZECll: Commissioner Carr.
12 COMMISSIONER CARR No.
13 Cl! AIRMAN ZECil Comruissioner Rogers.
14 COMMISSIONER ROGERS: Well, I think just really 15 the collectivo dose question which is the one that is most 16 troublesome,and I wonder if c ther of you two nontlemen who ,
17 are positioned to the inclusion of a specific collective dose 18 in the policy statement could say anything about how the 19 concerns that are obviously in back of introducing this into 20 the policy statement could be addressed without setting a 21 collective dose limit in the policy statement?
M What is your opinion as to the validit) in a sense 23 of these concerns and how they could be addressed without 24 putting them in as a specific limit? You' suggested that you i
25 are in coposition to that but there clearly is an issue out
, 60 1 there that is troublesome, and how would you suggest that we t
2 address that issue?
3 DOCTOR TAYLOR: Well, as I understand the problem 4 there, if you were to set a particular number as a BRC level, 5 you would have to do that after a determination had been 6 made that individuals were not going to be exposed above 7 whatever level it may be that you have set. At the same a time -- well, if you do that, you can stop. You do not need 9 to be concerned any further with the collective dose that 10 applies to the people below that level.
11 Now, am I saying something that seems to be in 12 conflict there? I think it's that simple.
( 13 COMMISSIONER ROGERS: Well, it's clear that 14 everybody doesn't agree that that's the case because our 15 advisory committee on waste seems to feel that there should 16 be a collective dose ltmit and has some ideas about the size 17 of it and so on. So, there must be an issue here that 18 reasonable people see in a different way, and I wonder if 19 there is some way of approaching that issue which is a little 20 different from we need it or we don't need it and we just 21 thrash it out on that basis.
22 Can that issue be illuminated a little bit and 23 dealt with in another way? (
24 DOCTOR TAYLOR: I don't know how you troat an issue
\
25 like that. That is made up of a collection of opinions. This
, 61 1 commit'.ee you mentioned, I am not familiar with the name.
(
2 MR. ALEXANDER: Dave Mohler's.
3 DOCTOR TAYLOR: Huh.
4 MR. ALEXANDER: Dave Mohler's committee'.
5 DOCTOR TAYLOR: All right, Dave Mohler's committee.
6 Cl! AIRMAN ZECil Advisory Committee on Waste.
? 7 DOCTOR TAYLOR: Okay, right. Well, I know Dave 8 Mohler very well and I also know very well his attitude on 9 this question and Dave, quite honestly, probebly believes
. 10 that a large number of people exposed below one millirem can 11 add up to some kind of an undesirabic cumulative dose. I 12 don't think so and the NCRP doesn't think so. They say so 13 cpecifically in their report, if I understand what is 14 attributed to the advisory committee. I am not familiar ,
15 with -- I know of that report but I am not familiar with the 16 details of it.
17 MR. TIPTON: Excuse me. In our discussions and ar.
18 I said in my statement, we feel at these low levels if you 19 set the limit at the individual you are protecting the N population. Now, in the briefing of the staff, saying that 21 you can use the collective dose to assure that no more than 22 100,000 people get this ten-millirem, in preparing the l 23 petition that we are preparing, we found that *.he maximum 24 exposed individual for this ten-millirem'was actually the s
25 truck driver in getting the material from the plant to the
o
. 63 1 landfill itself. And, looking at the overall issue of who 2 would be exposed, clearly you have to look at the most 3 exposed individual and we fool that that is the driver 4 himself.
6 We don't see how you use the 100-person rem at 6 these lower levels in terms of the protection of the pu'alic.
7 DOCTOR TAYLOR: If you were to --
8 COMMISSIONER ROGERS: Well, is it --
9 DOCTOR TAYLOR: Excuse me. Go ahead. .
10 COMMISSIONER ROGERS: I was just going to say is it i
11 really just another way of stating the linear hypothesis 12 really?
13 DOCTOR TAYLOR: No.
14 COMMISSIONER ROGERS: Well, because it in taking a 15 small number and multiplying it by a big number and getting 16 something that is measurable and that small number is really 17 one that comes out of the linear hypothesis.
18 MR. TIPTON: The other problem you have sometimes 19 with levels like this, if you were to multiply the potentici -
20 exposed individuals, et cetera, and you say that you have a 21 100,000-person rem of exposure, we are talking ten to 20-22 millirem, and you divide that by a factor of 10,000-person 23 rem per cancer, you could say that you have a statistical 24 cancer, statistical fatality due to these types of exposures 25 when in fact, as the staff has presented, you are looxing at
P
. 63 1 the safoty goal numbers in terms of the incremental additional
{
2 risk to the public from these types of levels. So,' one of 3 the problems you have is public perception of this running 4 the code and running out the numbers and then dividing by a a factor, and statistically you have a fatality when in fact 6 you sit here and say how is that possible? That's part of 7 the problem.
8 DOCTOR TAYLOR: That question of public perception 9 is one of the key issues here. When you think about it in a to si*mple way, if you were to set a level of ten-millirems a 11 year as below regulatory concern, you are saying that nobody 12 who is exposed to those lower levels is going to stand an
( 13 appreciable likelihood of being harmed. That's what you are 14 saying. Now, I don't care whether that happens to one person 15 or ten persons or 10,000 persons, it still isn't going to 16 produce an appreciable harm unless you get down to the point 17 of speculating how many appreciables make one harm. It gets 18 you into almost ridiculous numbers in my opinion.
19 MR. ALEXANDER: Commissioner, in answer to your 20 question about alternatives, the position of our society, as 21 I mentioned when I introduced Doctor Taylor, is that if you 22 do find it necessary to establish a collective dose criteria, 23 that we recommend that you accept the NCRP advice to exclude 24 from the dose calculation anyone who receives less than one
\
25 millirem per year. That seems to be a viable alternative.
. 64 1 DOCTOR TAYLOR: But one thing, Bob; if the NRC were f
2 to set a level of ten instead of one, which the NCRP uses, 3 this exclusion of the requirement for the cumulativo dose 4 would still apply.
5 MR. ALEXANDER: Yes.
6 COMMISSIONER ROGERS: All right. Thank you very 7 much on that.
8 CHAIRMAN ZECH: Well, it seems to me that as far as 9 the collective dose is concerned, if there is no other reason, I
10 it may have some value in order to help us to put in as plain 11 language as we possibly can what is the potential harm to the 12 public. It is very difficult when we talk millirem and
(
13 micro-curies and all kinds of other -- echo-curies and 14 different measurements of radiation. The general public, I 15 have come to appreciate, has a very dif ficult time understanding '
16 what these numbers are and what is the potential harm. And, 17 if we can say it has one in 10,000,000 or one in 50,000,000 18 or something like that in as simple of terms that people can 19 understand, I think it is, frankly, an obligation that we 20 all have to try to come up with something that says very 21 truthfully, very honestly, the best scientific knowledge we 22 have and put it in as plain language as we can and perhaps
)
23 even if the collective dosage isn't all that valuable from a f
24 certain standpoint, it seems to me that it could be valuable 25 if it will help us to explain to the general public exactly
. . 65 1 what we are talking about.
2 COMMISSIONSR ROBERTS: I tend to think it would 3 obfuscate the.whole matter more.
4 CHAIRMAN ZECH: Well, that's possible. We should 5 s link about it. It seems to me that it would have merit to e try to come up with some way to explain what numbers we are 7 talking about and what harm, if any, in these low numbers e there would be. I'm sure there are different views on this e as Commissioner Roberts just pointod out. But to me it is a 10 challenge end it's an obligation and responsibility we have 11 to try to be as truthful and honest as we can and say what wo 12 mean, rather than talk about it in these very scientific 13 te rms . This is something that I think is very important.
14 DOCTOR TAYLOR: Well, I think --
15 CHAIRMAN ZECH: Doctor Taylor.
16 DOCTOR TAYLOR: Yes. Well, I think in your process 1 17 of arriving at a suitable number for BRC, you certainly 18 indeed do have tc go through just what you are talking about 19 just to show publicly what it is you have done. But once you 20 have done that to demonstrate the number that you have sek, 21 when you reach the point of exercising your BRC concept, you 22 don't have to keep track of anything that happens in the D region below that level.
24 Now, as I. understood, you are sug'gesting that you 25 might have to continue to do that.
4
- . 66 1 CllAIRMAN ZECH: No, I don't mean to do that at all.
2 I am thinking about two things. One is, first cf all, what 3 is the right number, conservative number, that we as a 4 regulatory body using all the expertise and advice we can 5 gather, what is the proper number that we should place on i
6 it for below regulatory concern? 'tha t is a very real 7 responsibility we have --
8 DOCTOR TAYLOR: That's right.
9 CHAIRMAN ZECH: -- we are trying to exercise. But 10 in addition to that and aside from that really, after we have 11 made that judgment or while we are making that judgment, what 12 is the best way we can explain and say in layman's language
- 13 what we have done and be very honest and truthful about it 14 and have a clear conscience? That's what we have done and 15 here is why we have done it and here is what we have done.
16 It's very dif ficult to explain these health physics terms 17 and I'think it's important we try to do so. ,
i 18 DOCTOR TAYLOR: I think it is crucially important 19 that you provide an explanation that the public can 20 understand. I have been trying to do this in my own small 21 way for 15 or 20 years since this situation has been getting >
22 somewhat out of control in my opinion. But the whole question 23 will hinge upon public conception of what the Commission is 24 doing. You have to put every fact out but, in addition, you 2 have to explain those facts so that people will understand l
l l
l
. 67 1 them in a language that they can understand.
2 CHAIRMAN ZECil: That's exactly what I'm trying to 3 do too. I think we need your help to do that. That's the 4 only reason I am saying that perhaps this collective dosage 5 has some merit.
6 COMMISSIONER CARR Mr. Chairman, I spent two days 7 trying to understand collective dose and I consider myself 8 an average member of the public and I cannot yet see any 9 rational explanation for a collective dose as to what it adds
. 10 to the problem. I have tried it all. I have discussed it 11 with the proponents and the opponents and I cannot como up --
12 it just doesn't make sense to me to use it for anything.
( 13 CHAIRMAN ZECH: The only thing that makes sense to 14 me is if you say below regulatory concern is ten millirem or 15 whatever it is, what does that mean? What does that mean?
16 And, to me, by itself it may not mean much but if you can say 17 it means that in a 50-year period you can expect to have 12 18 to 25,000,000 deaths and what this below regulatory concern j 19 means is that you would have one more.
- 3) COMMISSIONER CARR: Well, that's not the number that 21 we are talking about.
l 22 CliAIRMAN ZECH: Well, whatever, what I'm saying 23 is -- the numbers aren't important -- but what I'm saying is 24 that some way of saying in as plain language as we can what 25 we are doing. To me, that is perhaps the greatest value of
- 68 1 using a collective dose, or call it some other name but I am e
2 just trying to say that I think my personal feeling is the 3 general public is pretty smart and they deserve to know the 4 answer and I want to put it in as plain language as I can. i 5 I think if we do that, they will understand it and we will 6 have done a service. I have great confidence in the public 7 when they know the facts. I do believe that this collective 8 dose -- call it what you want -- is a method at least to e.ry 9 to explain what we are doing, and I think it is important we 10 try to do that.
11 MR. L MIS : Our society can help in that regard.
12 CilAIRMAN ZECH: What's that?
13 MR. LA!!S : Our society can helt in that regard.
14 I'm sure it can.
15 Cl! AIRMAN ZECll: We need help. We are asking for 16 help. At least I am anyway.
17 MR. LAHS: We can develop that to get it before the 18 public.
19 CHAIRMAN ZECH: Commissioner Carr.
b4 COMMISSIONER CARR: Let me add one more thing. In 21 trying to explain it to me, they tried to convince me that if 22 you had a lot of these sources that could expoav people up to
%3 en MR, then you ought to worry about all of these soutcos 24 and where they come from, and finally you are going to have
%5 to worry about a collective dose of the population. I said i
0
. 69 I why don't we in lieu of that worry about the individual 2 source that is causing the radiation and measure it and 3 control it at that level, instead of trying to control it 4 across a public that you can't really define? And, I would 5 like them to discuss that in the workshop, whether instead 6 of the collective dose we can look at the particular product 7 that is causing the dose and see if there is not some limit 8 i we can set on that and say you can't put this out in the 9 general public.
~
10 CllAIRMAN ZECH: Well, I think I would agree, that 11 is a fundamental concern that certainly should be discussed 12 and that we should be aware of.
13 COMMISSIONER CARR I tried to find out what the 14 100-person rem per year, what would be the limiting product 15 that would cause you to get to that. When would this come 16 into effect and what would it mean to the people if we set 17 it or what is the difference between setting it at 100-person 18 rem and 10,000-person rem except in the nuubers here? I was 19 unable to come up with a satisfactory answer that I could M understand.
21 CllAIRMAN ZECil: Well, that's what we are trying to 22 find out. We are asking is there one and is there a way that 23 the number we could out out is sensible, is honest, is 24 meaningful? That's what we are trying to find out. We are 2 asking for help from the experts. That's what we are here for .
70 1 DOCTOR TAYLOR: I am sure it can be done and the 2 biggest part of the problem, however, is going to be again 3 to find a way of presenting that to meet the public idea of 4 what is being talked about. You mentioned complex terms 5 using just collective dose as a simplification of the real 6 term. Just for your amusement, I will read you the sentence 7 now on that. It is further recommended that assessments of a increments of collective annual effective dose equivalents 9 -- that's the right word to use. That's boon reduced to 10 collective dose.
11 Now, there is a problem that we have of reducing 12 that fine scientific idea down to something that the public 13 can understand.
14 MR. TIPTON: And. I think also the public 15 understands comparisons of risks. I think when you had your 16 briefing with the staff before, they indicated that a round 17 trip flight to the west coast was around five-millirem 18 exposure. The public understands this ' risk relative to other 19 risks. So, you may even icok at it from that standpoint. It
, 20 is easy to understand. I think they woulu have difficulty 21 with person-rem. I mean what is a person-rem and what is the 22 affected population we are talking about? Is it within ten 23 miles of the landfill? Why just ten miles? Why isn't it 100 24 miles, et cetera? And, you play that of f and 't know, it's 2 according to who you are talking to. But whe: ilk P
. \
o 71 1
1 relative to other risks that they understand, it's easier l 2 for them to understand what we are saying at these levels of 3 radiation, j 4 Cl! AIRMAN ZECll: Well, let me emphasize just one 5 final point. There are two issues again. One is our 6 responsibilities for the public health and safety. We don't 7 want to harm the public. That's very real and that is what 8 we have got to decide. That's our responsibility. We are a using the scientific community to help us make that to determination.
11 The second thing is how do we explain it and make 12 it understandable to the public. There are two different 13 issues very separate in my judgment. The one is our 14 responsibilities for public health and safety are very real.
15 That is our responsibilities. They expect us to do and that 16 is what we are trying to do. But in addit.on i to doing that, 17 when we have done that, it seems to me we ought to be able 18 to try to say in layman's language exactly what we have done.
19 MR. TIPTON: And, we support those.
20 CliAIRMAN ZECII: Well, are there any other questions 21 or comments?
M COMMISSIONER CARR: I have got one.
23 CIIAIRMAN ZECil Yes.
24 COMMISSIONER CARR As I say, the whole thing boils i 25 down, and I hope we can work it out in that workshop, but the
o , 72 1 justification of the practice, this so-called not benefit, 2 I don't know who is going to decide what is not in the 3 benefit or how net is going to be determined. On the issue 4 of collective dose then, I think, before we leave, we ought 5 to clear up this comment in the paper that says that NEPA, 6 the National Environmental Policy Act, iequires that the 7 collective dose be figured.
8 Can the counsel provide any information on that?
9 MR. PARLER: Well, in addition to the radiological 10 health and safety responsibilities, this agency is subject to 11 the National Environmental Policy Act. The National 12 Environmental Policy Act certainly does not, in my judgment, 13 require that a particular collective dose be set. But in 14 either deciding whether an environmental assessment is 15 required or doing an envircnmental assessment, certainly the 16 societal impact would have to be considered.
17 Therefore, 't would seem to me that in order to do 18 that, a range of alternatives could be considered or a ban 19 without setting any particular dose level. But after you go M through the analysis, you should be left with some certainty 21 as to what the societal impact would be. So, you have to do 22 something but you don' t have to set a precise number.
23 CHAIRMAN ZECH: All right. Any other questions or 24 comments?
25 (No response.)
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. 73 1 CHAIRMAN ZECH: All right. Well, let me then on 2 behalf of the Commission thank you Doctor Taylor very much 3 and Mr. Tipton and the staff for this presentation this 4 morning. It is a very important issue. It has been'around 5 for a long time. We have a responsibility to attempt to 6 resolve it. I think the international conference certainly 7 should be very helpful.
8 I would ask my follow Commissioners, I believe we 9 have before us SECY-88-257 that asks for -- the staf f was
. 10 asking for our authorization to go to this international 1 11 conference and present these policy views. Mr. Stollo has 12 also suggested perhaps that we go to the public first and j
13 then go again after the meeting.
14 I would prefer, frankly, to go to the international i 15 conference I think and then see what they have to say and 16 then go out'with public comments later but since Mr. Stello 17 has made the proposal that 49 go either one way or the other, 18 I would ask you add that to SECY-88-257 and perhaps act on ,
19 that as soon as we can so that the staff will have our :
M guidance before they go to the international conference.
21 If there are no other questions or comments from ,
22 my fellow Commissioners --
23 (No response.)
24 CHAIRMAN ZECH: -- thank you very'much. We stand s
M adjourned. l (Whereupon, at 11:50 a.m., the Commission meeting was adjourned.)
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CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the U.S. Nuclear Regulatory Commission entitled: BPIEFING ON STATUS dF EFFORTS TO DEVELOP A BELOW REGULATORY CONCERN POLICY TITLE OF MEETING: Public Meeting PLACE OF MEETING: Washitigton, D.C.
DATE OF MEETING: September 16, 1988 l
were transcribed by me. I further certify that said transcription is accurate and complete, to the best g of my ability, and that the transcript is a true and accurate record of the foregoing events.
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Coenission Briefing on Generic BRC Friday, September 16, 1988 Good morning. I am Tom Tipton, Director of the Operations, Management and Support Services Division of the Nuclear Management and Resources Council (NUMARC). Byron Lee and Joe Colvin are on travel and send their regrets for rot being able to be here today. I'd like to thank the Commission for the opportunity to appear before you at this meeting to present a statement on behalf of NUMARC with input from representatives of Edison Electric Institute (EEI), Electric Power Research Institute (EPRI), Utility Nuclear Waste Management Group (UNWMG) and U.S. Council for Energy Awareness (USCEA).
With me today are the following industry representatives; Mary Birch, Technical System Manager, Radwaste Engineering, Duke Power Company, and Chair of EPRI's BRC Owners Group Technical Advisory Committee; Lynne Fairobent, NUMARC Project Manager; Pat Robinson, Director of EPRI's Below Regulatory Concern (BRC) Owner's Group; Steve Kraft, Director of UNWMG; and Dixon Hoyle, Project Manager, Nuclear Fuel Cycle, USCEA.
The nuclear industry has supported and continues to support NRC's efforts
- to designate levels of radiation that are Below Regulatory Concern. Since the generic BRC issue involves several industry organizations and addresses a generic issue, NUMARC is responsible for coordinating these industry l
activities. To accomplish that, we established a BRC Ad Hoc Advisory Committee, which has representation from all industry groups addressing l
l different aspects of the issue. A draft industry program plan is being I
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prepared and will be distributed in the near future. It describes the range and scera of industry activities relating to the BRC issue and the key milestone dates. We plan to make it available to your staff so that you will be fully awa e of industry's programs.
However, we think it is important to briefly highlight today some of the industry activities already completed and those in progress that address this issue and then mention some important points for your future consideration. Again, we appreciate you allowing us this opportunity.
There have been several detailed industry studies addressing the issue of CRC dating back to the late 1970s. Some examples are identified in Attachment A to my presentation.
In July 1984. EEI and UNWMG filed a petition for rulemaking with the NRC regarding the disposal of radioactively contaminated waste oil from nuclear power plants with levels of radiation that should be classified as being below regulatory concern. We are pleased that NRC published for comment in the August 29, 1988 Federal Register a proposed amendment to its regulations to permit the on-site incineration of slightly contaminated waste oils generated at nuclear power plants. The nuclear industry will be submitting comments on the proposed rulemaking.
The industry has also been involved in related activities. Extensive
! comments on the proposed revisions to 10 CFR Part 20 were provided in October 1986 by the former Atomic Industrial Forum and EEI: Detailed comments on 2
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. NRC's BRC recommendations were included. The industry also commented extensively on NRC's Advance Notice of Proposed Rulemaking on Radioactive Waste Below Regulatory Concern published in the December 2,1986 Federal Register. These comments included a strong endorsement of the Commission's proposal to develop BRC regulations.
NRC published in the August 29, 1986 Federal Register a policy statement and staff implementetion plan regarding, "expeditious handling of petitions for rulemaking to exempt specific radioactive waste streams from disposal in a licensed low level waste disposal facility." This policy statement provided the long-sought opportunity for the nuclear industry to pursue the exemption of wastes with very low activity levels from NRC regulations.
In response to the August 1986 Policy Statement, EPRI and UNWMG initiated a joint program in early 1987 to develop a petition for ruir. making to exempt very low level waste produced at nuclear power plants. EPRI is providing the research and technical data to support the petition, and UNWMG is providing program support, including legal support and drafting a petition. The EPRI .
research effort is nearly complete. It alone represents an expenditure of approximately 2.2 million dollars. The present target is to submit the petition by the end of this calendar year.
The petition will propose that the regulations allow the disposal of slightly contaminated wastes in on site landfills, off-site sanitary landfills, and on site and off-site incinerators. It will fully comply with the detailed criteria set forth in the Commission's August 1986 Policy Statement and the 3
_z staff's implementation plan, and will therefore qualify for expedited processing.
Now, I would like to briefly summarize some important points for your consideration during future discussions on the issue.
First, it is important that any NRC action identifying a level of radiation risk or dose holow which government regulation would be limited or unwarranted be consistent with, and not negate in any way, the August 1986 policy statement. We need to preserve the options it provides as well as the investment the industry has made in preparing the petition.
Second, we feel that a process should be established to determine appropriate BRC levels, including the performance of a cost / benefit analysis for higher BRC exempted dose levels. Less rigorous analyses would be required for lower dose values. We generally support an approach similar to that presented by the staff at the Septemoer 13, 1988 meeting of the Advisory Committee on Nuclear Waste. Prior industry comments on the issue support individual doses in the range of 10-20 mrem per year as the generic BRC.
Third, since protection of the individual assures adequate protection
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of the overall popuiation, the establishment of an annual collective dose (person rem) standard for BRC is not appropriate.
. Finally, it is our understanding that the staff currently intends to make BR standards a "matter of compatibility" for Agreement State Regulatory 4
Programs. In order to realize the full benefits from the Commission's BRC initiatives, it is crucial that BRC standards be adopted by Agreement States identical with federal requirements, in a manner similar to the Commission's other radiation protection standards.
In conclusion, the industry strongly supports initiatives to address the BRC issue, as reflected in the work that has been initiated over the past decade. Further, the industry believes that the development of BRC is important to the conduct of good radiation protection programs while at the same time making it possible to minimize the expenditure of re:o.rces on matters that pose trivial levels of risk.
We support the need to address the generic BRC issue in a timely manner and encourage the continued exchange of information as it becomes available.
Establishing regulatory cut off values would assure that our limited resources are being used most effectively in protecting public health.
Thank You.
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Attachment A EXAMPLES OF INDUSTRY STUDIES COMPLETED ATOMIC INDUSTRIAL FORUM AIF/NESP-016 (1978): "De Minimus (sic) Concentrations of Radionuclides in Solid Wastes" AIF/NESP-035 (1986): "Evaluation of the Potential for De regulated Disposal of very Low level Wastes from Nuclear Power Plants" AIF/NESP-037 (1986): "A Guide for Obtaining Regulatory Approval to Dispose of Very Low level Wastes by Alternative Means" EDISON ELECTRIC INSTITUTE GP-33040 (1981): "The Feasibility of Establishing a 'De Minimis' Level of Radiation Dose and a Regulatory Cut-off Policy for Nuclear Regulation" GP-R-72005 (1982): "Summary of Potential Benefits of Proposed Regulatory Cut Off Policy Based on De-Minimis Radiation Dose Criteria - Results of a Survey of Nuclear Utility Personnel" ELECTRIC POWER RESEARCH INSTITUTE EPRI NP-3299 (1983): "Segregation of Uncontaminated Dry Active Waste" EPRI NP 3370 (1984): "Identification of Radwaste Sources and Reduction Techniques" EPRI NP-5099 (1988): "Update Characterization of Radwaste Sources, Vol. I and Vol. 2 EPRI NP-5670 (1988): "Below Regulatory Concern Owners Group: Evaluation of Candidate Waste Streams" 1
EPRI NP 5671 (1988): "Below Regulatory Concern Owners Group: Radionuclide Prioritization Study" EPRI NP 5672 (1988): "Below Regulatory Concern Owners Group: Selection of Plants for Sampling Program" 6
e PHYSICS SOCIETY H E ALTH September 8, 1988 Commissioners Lando W. Zech, Jr.
Thomas M. Roberts Kenneth M. Carr Kenneth C. Rogers U.S. Nuclear Regulatory Commission Washington, DC 20555 It has come to the attention of the He'ich Physics Society that, because of concern over the unwise use of available trained manpower and resources associated with the regulation of radiation exposures at very low doses, the Nuclear Regulatory Commission is considering the adoption of a policy to define a meaningful generic level of exposure below which it would have no regulatory concern. Although the unnecessary regulation of very low-level radiation creates employment opportunities for our members, we would like to inform you that this Society shares your concern and is prepared to provide consensus scientific assistance and support for your position. In particular, it is the position of the Society that the efforts mentioned above are in many cases not commensurate with the risks, if any, that are averted.
The Health Physica Society, founded in 1956, has a membership of more than 6,400 health physicists and other scientists who specialize in the protection of people from ionizing radiation, including physicists, chemists, radiobiologists, epidemiologists, physicians, engineers and mathematicians drawn from industry, academia; research and medical institutions, national laboratories and governmental agencies. The Society is believed to fully encompass and represent consensus technical opinion in the field er radiation protection and health effects.
Today a considerable fraction of the regulatory effort to concerned with radiation exposures that are much smaller than those received from variations in natural radiation due to altitude changes and other causes. We currently suffer from what appears to be an irrational public fear of low levels of radiation exposure; this has been fostered, in part, by associated governmental pressures to further reduce them below risk levels found and accepted in nearly all other factors of life. This, in turn, has resulted in the incurrence of inordinate pressures on all phases of the radiation industry, the cost of which is ultimately passed on to the public. We believe a real, and much greater saving of life could be accomplished by the alternative expenditure of our resources on safety operations where the risks are clearly demonstrated, as compared with the low-level radiation risks which are so miniscule that they may never be unambiguously established.
6309290n 70 GSO908 FDR 10CFR PT9.7 PDC
6 Ceptember 8, 1988 Page 2 It has never seemed logical to try to regulate radiation exposures that are miniscule relative to those we receive from nature. We believe that the Commission's objectives can be accomplished within the framework of the existing standards of radiation protection as recommended by the International Commission on Radiological Protection (ICRP), and the National Council on Radiation Protection and Measurements (NCRP). These bodies have recommended dose limits for the public that are far below the level where specific health effects have been observed for humans. It is not known whether any health effects in the general range of those recommended dose limits do or do not occur. If they do occur, they occur so infrequently that present scientific methods are incapable of detecting them using the best laboratory and epidemiological methods.
The system of dose limitation recommended by standards bodies does more than provide dose limits which are not to be exceeded without regard to cost-benefit considerations. In addition all radiation users are admonished that doses should be "kept as low as reasonably achievable (ALARA), social and economic considerations being taken into account", and that unnecessary exposures should be avoided. This is not a standard in the sense of a dose limit but is an essential advisory to be applied on a case-by-case basis. The dose limit, when coupled with the ALARA concept, provides an averaRe individual (or collective) dose that in associated with an acceptable risk. A BRC level, would, in effect, truncate governmental involvement in the implementation of the ALARA concept, placing further implementation on an entirely voluntary basis. Thus we believe that the BRC level should, at least in theory, be near the threshold of a public risk of sufficient magnitude to warrant governmental intervention in the lives of its citizens. The current NRC safety goal for operation of a nuclear-power plant is theoretically associated with doses of some 10 to 20 millirems in a year for an entire lifetime, which would seem an appropriate range in which to start considering a BRC level.
Pertinent technical issues are addressed in more detail in the enclosed attachments No. I and II.
Respectfully submitted by the Health Physics Society, y Nh Lauriston S. Taylor Past President Health Physics Society
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ATTACHMENT NO. I
- 1. Conservatics of current radiation protection standards. The recommendations of the ICRP and the NCRP are put forward with extreme caution and in expectation that the responsible bodies (e.g. NRC) will apply the necessary politic adjustment of practical limits to meet the technological and social needs of the nation. Because of the absence of observed health effects in the low dose region (below the order of 5 rem in a year), both the ICRP and NCRP make the conservative assumption that the frequency of occurrence of health effects, per unit of dose at the low dose levels in the range of the dose limits, is the same as at high doses where health effects have been quantitatively observed and extensively studied in both humans and animals.
This process allows the theoretical establishment of upper limits on the number of effects--if any--that might occur in the low-dose range. There has been remarkable agreement among the ICRP, NCRP, NAS, and UNSCEAR on all of the quantitative methods by which the effects should be estimated. At the same time there has been agreement that, if used for projecting Ital effects that will occur following low-level exposures of the public, the assumption of proportionality is inappropriate and misleading, and should not be so used.
- 2. Balancing costs and dose reduction. The taking of social and economic considerations into account is the nemesis of the radiation regulator and is the least understood by the public. Standards bodies have emphasized .
that in the commitment of resources to reduce doses below the dose limits, I there should be an appropriate balance between resources committed to reduction of dose and the real benefits derived in the subsequent reduction of !
health effects. It is recognized that a point is reached where the effort (cost) required to further reduce dose exceeds the benefit from the small !
incremental reduction of health effects that is theoretically achieved. In such cases the further expenditure of resources to reduce dose is not justified. While several regulatory limits have been determined using this approach, it appears that a generic BRC level would more appropriately be based on other considerations such as an incressr. in the theoretical risk as was used in the development of the Commission's safety goals.
- 3. The public perception of safety. Failure to clearly explain the i
ALARA concept has, in some instances, resulted in public perceptions of health effects from very low-level radiation which are irrational and without factual f basis. This, in turn, has led to the needless expenditure of substantial '
resources by individual members of the public, and by public agencies, because of an unreasonable concern with exposure to low-level radiation. This is all done in the name of reducing health effects which, if they exist at all, are l so small as to be meaningless in comparison with the general health effects suffered by the public and as caused by ordinary substances to which people are exposed in everyday living. This type of unwarranted 6sneern with possible health effects from low-level radiation exposure can also lead to a failure to take advantage of the use of rs.diation-related technologies, even though in many cases a radiation technology may be the method of first choice.
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- 4. The Public Perception of Risk. Perhaps the most difficult phase of the BRC problem is that of dealing with the public's perception of radiation risks and its concept of safety of any kind. The average percon in the general public does not realize that there is no such thing as absolute safety. They see that if a given condition is not safe, it must be unsafe--that there is a sharp dividing line between the two. Webster defines safe as, "free from or not liable to danger of any kind; free from or having escaped hurt, injury or damage. . . ." Obviously, absolute safety is not obtainable for most human activities. Therefore the question is not "What is s safe level of exposure?", but "How safe is safe enought". We know that safety is a relative ters, but most of the public and the news media do not understand that. A major national effort is probably needed to educate the public as to what safety means and what they are to axpect of it.
- 5. Contaminated material. Our discussions at this juncture relate only to health effects in the population. A separate, but related, problem concerns levels of contamination of material that may be returned to industrial use. Under many circumstances such material may not pose any health problem but can introduce difficulties if, by chance, it should be incorporated into devices or instruments where extremely small amounts of radioactivity could interfere with their proper operation. Thus, contamination levels far below any conceivable risk to humans may still be a costly nuisance to the very few manufacturers of radiation instruments or certain shielding materials. Strict regulation of the many thousands of facilities at levels lower than those designed primarily for human riska vould be costly out of all propertion to the value of such contamination-free materials. When there is need, let it be a part of the manufacturing costs to find and test the required meterials.
- 6. Science and technology in radiation protection. There is another role of the Commission that must be undertaken, and recognized not only by the general public but the scientific community generally, and especially those in radiation science as distinguished from radiation protection practitioners (e.g., health physicists). With his normal background and training, the scientist speaks on the basis of facts or theories (or assumptions or models). For example in discussing possible low-level radiation health effects, he accepts the existence of meaningful data in the range above, say, 10 rem. Below 10 rem, his data are of questionable value, if existing at all, but it appears ao though the higher range data might (more or less) logically extend straight down to zero dose. When pressed, he speculates that if we could find some data in that unexplored low-dose range, it would almost l t certainly not be far out of proportion with the high-dose data. However, he can't say for certain that there are no effects in the low region since it has not been possible to obtain any data there at all. The best he can do is to point out that in such case there is a possibility that for any dese, no !
, matter how small, there must also be the possibility of some health effect. l l As far as the public is concerned, the associated low probabilities so unrecognized and Pandora's box has been opened. They believe that any radiation exposure whatever will lead to cancer. [
t d
- Attachment I (page 3)
- 7. The role of the Nuclear Regulatory Cammission. What is the point of all this? The point is that our scientifically derived radiation protection standards, by themselves, are inadequate for some radiation exposure situations, specifically for defining acceptable conditions of "safety" in the low-dose range. The only solution for this is a politic ,
decision by a properly authoritativa governmental organization, such as the Nuclear Regulatory Commission. (By politic, Webster means, "prudent and sagacious in devising and pursuing measures to promote the public welfare.")
The obvious step is that the NRC must establish, and make clear, its role in t the radiation protection standards arena, that 1) it is making the necessary politic utilization and adjustment of the scientifically derived radiation protection data, as far as they go, 2) it is accepting the responsibility for clari.ying the concept of nuclear safety, or relative safety, and 3) it is setting a level of radiation that is below regulatory concern.
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ATTACHMENT II In its more than 30 years of direct experience with the public and radiation protection, many points have come to the attention of the Health Physics Society that we believe should at least be thought about in considering the adoption of a BRC concept. Many of them are based on questions that are asked of our members, individually, or statements--and minstatements--that appear in the various news media. We are reasonably e,9rtain that you are already aware of most, if not all, of the items to follow but offer them, largely in outline, by way of emphasis. Some additional items are in amplification of statements in the preceding pages.
A. Examples. There is about a 70 area / year difference in the dose from external radiation one receives from natural sources, depending on whether one lives on the coastal plane or in the hilly areas in the West. (NCRP toport (3.) The higher exposure to radiation of people who live in the hills and mountains does not seem to make them less desirable to those who want to live there.
Average natural-background radiation levels vary by 100 milliren in a year. Studies have shown a generally lower cancer incidence rate at the higher background locations, thus indicating that a BRC below 100 area could be scientifically defensible.
The upper limits of risk that result from levels of exposure comparable to the variations in the natural background are well below the risks from commercial activities that are generally accepted as good neighbors in the communities in which they exist.
Normal living habits such as working on the 10th floor as compared with the 1st floor of a building, or living in Bethesda as compared with downtown Washington, add a few millirens per year to one's dose. So also does commercial flying, medical procedures and so on--none of which are normally considered in individual radiation exposure concerns.
Something is considered acceptably safe when extensive study and experiment demonstrate that one's individual chances of injury or accident are exceedingly small. It should be noted that nothing is absolutely safe, but that all activities and natural events have varying degrees of risk.
B. Data Lia11 112ns. In establishing 9ersonnel protection standards it is considered by some as scientifically ano morally defensive to use the "linear-nonthreshold" approach into the low dose regions as a practical expedient, because it overestimates the dose effect. However, it was never intended that risk evaluation be made using this approach.
i Attachment II (Page 2)
To postulate a large number of deaths from very lov exposures (leas than a single dose of 10 rems, or an annual dose cf 1 rem in a year) to a very large population is fundamentally indefensible; it communicates a misconception in the minds of the laypublic and legislators / administrators.
One possible reason for the lack of low-dose-effect data for humans is that such effects may r.ot exist. Another reason is the fact that very large exposed populations (millions of subjects) are required for statistically defensible studies that must extend over 25 to 50 years. Equally large unexposed, but otherwise control populations, are also required.
Estimated Population Size to Provide Statistically Meaningful Effects Values DOSE POPULATION SIZE 10 rad 50 thousand 1 rad 5 million 100 mrad 500 million 10 mrad 50 billion C. Judament in the absence of facts. Because the general public is not equipped by education and experience to evaluate complex technical matters, the government or some type of public body with suitable expertise must,1) develop guidelines, excluding conditions outside the area of knowledge, 2) base any guides on facts as far as they exist, 3) clearly define conditions where they do not exist and, 4) apply professional judgment in lieu of facts when necessary, but make the action clear. In the application of judgment, the reasons and need for any action that is not amenable to quantitative evaluation must be explained.
D. Possible objectinna. It is quite possible that some individuals or groups will bring charges of vested interests on the part of the Health Physics Society because of this submission. Such a claim is the opposite of common sense since the personal interests of health physicists would appear to be better served by more severe rather than apparently less stringent radiation protection regulations.
It can be foreseen that objections may be raised to the implementation of the BRC concept because of the frequently stated misconception that we "know nothing about the effects of lov levels of exposure." Objectiens may also be raised on grounds that "there is no such thing as a safe dose of radiation."
Both points are diocussed in Attachment I.
e pa ne
' m., UNITED STATES
[4j NUCLEAR REGULATORY C2MMISSION
- ' #, e. t,.( g3 ADVISORY COMMITTEE ON NUCLEAR WASTE
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- .[ W ASHINGTON. D.C. 20E44 September 15, 1988 The Honorable Lando W. Zech, Jr.
- p. Chairman ,. _
V.S. Nuclear Regulatory Comission Washington, D.C. 20555
Dear Chuirman Zech:
SUBJECT:
PROPOSED POLICY STATEMENT ON BELOW REGULATORY CONCERN During the fourth meeting of the Advisory Comittee on Nuclear Waste, September 13-14, 1988, we held additional discussions with the NRC staff relative to the development of a Proposed Comission Policy Statement on Exemptions from Regulatory Control for Practices Whose Public Health and Safety Impacts are Below Regulatory Concern (BRC). This topic was previously discussed with the NRC staff during a meeting ,of the ACRS Subcomittee on Waste Management on May 4,1988. The ACNW also dis-cussed this topic with the NRC staff during our second meeting, July 21-22, 1988, and reported to you on this subject on August 9, 1988. We also had the benefit of the document referenced.
As a result of these discussions, we offer the following coments:
- 1. The proposed exemption system is based on the risks associated with the exposures involved, and the system, if modified as suggested here, will be compatible with most relevant regulations and poli-cies of the NRC and other federal agencies, as well as those of international organizations.
- 2. We urge the adoption of dose rates up to 10 mrem (0.1 mSv) per year to individuals and annual collective doses up to 100 person-rem (1 person-Sv) as acceptable limits arising from a single exempted practice. Please note that this is a different use of the cose limits than is proposed in the draft Policy Statement. Provisions should be made to ensure that individuals within any population group are not exposed to any combination of exempted practices that results in dose rates greater than one to two times the dose rate limit. Experience indicates that such occurrences should be rare.
- 3. The current draf t of the proposed Policy Statement is in need of extensive revision, partly to comply with the recomendations made under item 2, above. Additional items that need to be addressed include:
ge% fem 3/P
y The Honorable Lando W. Zech, Jr. September 15, 1988
- a. The draft of the proposed Policy Statement should clearl specify 10 mrem (0.1 mSv) per year and 100 person-rem (y1 person-SV) per year as the limits for individual and collec-tive dose rates, respectively. The ancillary use of a 100 person-rem (1 person-SV) per year limit as a guide to the necessity for ALARA analysis should be removed (see item b, below).
- b. There is a need for a much,. clearer statement relative to the role and application of the principle of "justification" in assessing practices being considered for exemption.
- c. Instead of discussing dese rates at which collective dose calculations should be truncated, it would b^ better to do a complete calculation, and include within the data a tabulation of the number of people within each of several dose rate ranges.
- d. The section pertaining to the linear nonthreshold hypothesis needs to be clarified. One approach wouU be simply to include a brief statement that risk (cancer) estim 'es should be based on the assumptien that the linear ni 4reshold !
hypothesis applies and that this approach will 641 t in conservatism in the resulting estimates.
- e. Since its use represents a change in NRC policy, the concept of the Effective Oose Equivalent should be defined within the Policy Statement. In a similar manner, since SI units are in comon usage throughout the world, all dose rates and collec-tive doses should be expressed in these units as well as in the conventional units.
- 4. As the proposed Policy Statement correctly points out, the Agree-ment States will play an important role in the implementation of i the proposed exemptions. For this reason, it is important that the Statement be formally submitted to the Conference of State Radia. '
tion Control Program Directors for review and coment.
The resulting document, when properly revised, will represent a pio-t neering effort in nuclear safety regulation, will help conserve those of our resources that are available for the control of environmental and
', public health problens, and should receive strong support from the '
professional radiation protection comunity. We believe that the l proposed Policy Statement, if revised as suggested above, will serve
The Honorah'e I.ando W. Zech, Jr. September 15, 1988
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we, as a starting point for the position to be stated at the upcoming i cernational meeting on this subject.
Sincerely, i JC ,
Dade W. Moeller l r Cha44 man !
1
Reference:
Memorardum dated September 8, 1988 from Bill M. Morris. Office of ;
Nuclear Regulatory Research, NRC, to R. F. Fraley, Executive Director, AChW. transmitting Proposed Commission Policy Statement (undated)
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