ML20154R328
| ML20154R328 | |
| Person / Time | |
|---|---|
| Issue date: | 05/31/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1671, NUDOCS 8806070272 | |
| Download: ML20154R328 (159) | |
Text
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UNFFED STATES O
NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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l In the Matter of:
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SUBCOMMITTEE ON OCCUPATIONAL AND
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ENVIRONMENTAL PROTECTION
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SYSTEMS
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May 31, 1988 "8
PAGES:
1 through 113 h
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LOCATION:
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8806070272 080531 PDR ACRS T-1671 PDR
1-PUBLIC NOTICE BY THE 2
UNITED STATES NUCLEAR REGULATORY COMMISSIOtPS 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5 6
7 The contents of this stenographic transcripc of the 8
proceedings of the United States Nuclear Regulatory 9
Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACRS Staff and no participant at 13 this meeting accepts any responsibility for errors or
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14 inaccuracies of statement or data contained in this transcript.
15 16 17 l
18 19 i
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21 22 23 l
24 25
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Heritage Reporting (202) 628 ',
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UNITED STATES NUCLEAR REGULATORY COMMISSION 2
ADVISORY COMMMITTEE ON REACTOR SAFEGUARDS 3
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In the Matter of:
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4
)
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5 SUBCOMMITTEE ON OCCUPATIONAL
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AND ENVIRONMENTAL PROTECTION
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6 SYSTEMS
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)
7'
- Tuesday, 8
May 31, 1988 9
Room 1046 1717 H Street, N.W.
10 Washington, D.C.
20555 11 The above-entitled matter came on for hearing, 12 pursuant to notice, at 8:30 a.m.
O 13 BEFORE:
DR. DADE W. MOELLER Professor of Engineering in Environmental 14 Health, and Associate Dean for Continuing Education, School of Public 15 Health, Harvard University Boston, Massachusetts 16 ACRS MEMBERS PRESENT.:
17 MR. CARLYLE MICHELSON 18 Retired Principal Nuclear Engineer Tennessee Valley Authority t
19 Knoxville, Tennessee and Retired Director, Office for Analysis 20 and Evaluation of Operational Data U.S.
Nuclear Regulatory Commission 21 Washington, D.C.
22 MR. CHARLES J. WYLIE Retired Chief Engineer 23 Electrical Division Duke Power Company 24 Charlotte, North Carolina 25 HERITAGE REPORTING CORPORATION -- (202)628-4888
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CONS _UL__T_A_N_T_S:
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Shapiro j
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Carter-f 3
W. Cool 4
ACRS COGNIZANT STAFF MEMBER:
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Al-Igne j
6.
NRC STAFF PRESENTERS:
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' Donald Cool i
Bill Morris 8
Hal Peterson 9
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P_ R O C E E D I.!! G S.
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CHAIRMAN MOELLER:
The meeting will now come to i
3 order.
4 This is a meeting of the ACRS Subcommittee on 5
Occupational and Environmental Protection Systems.
I am Dade 6
Moeller, the Chairman of the Subcommittee.
The other ACRS r
7 members in attendance are Charles Wylie and Carlyle Michelson.
8 We have two consultants with us, Jacob Shapiro and Melvin 9
- Chrter, 10 The purpose of today's meeting is to discuss the j
11 proposed revisions to 10 CFR Part 20, quote, "Standards for i
12 Protection Against Radiation" unquote.
Mr. Alfredo Igne is
()
13 the cognizant ACRS staff member for today's meeting, and he is 14 sitting on my right.
15 The rules for participation have been announced as l
16 part of the notice published in the Federal Register on May 17 16, 1988.
The meeting is being conducted in accordance with 18 the provisions of the Federal Advisory Committee Act and the P
19 Government and the Sunshine Act.
20 We have received a request from Paul Stansbury, i
21 General Electric Nuclear Fuel and Components Manufacturing 22 Company, to make an oral presentation, and this will be 23 scheduled at the end of our formal discussion session which 24 will place it roughly about noon or shortly before noon.
25 If there is anyone else in attendance who would like f
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to offer some oral coma t: -
oe pleased to accommodate
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2 you if you will simply le Igne know.
3 For any member of the public speaking, or for the 4
members of the Subcommittee and its consultants, we request 5
that if you speak, you first identify yourself and speak with 6
sufficient clarity and volume so that everyone here can hear 7
what you are saying.
8 In the way of background for the meeting, I wanted 9
to offer some personal observations, and not that it will set 10 the tone for the meeting.
I don't think it will, because our 11 Subcommittesa members are quite ready to express independent 12 views if they have them, but I thought that several comments
.()
13 perhaps would be in order.
14 And my first one was that the report, the proposed 15 revisions do represent a tremendous effort on the part of the 16 staff, and it has been a many year effort with a multitude of 17 people being involved, and I believe all of us should 18 recognize that in preparing this latest version, there have 19 been certain difficulties.
They have tried to make it 20 compatible with both the recommendations of international 21 organizations such as the ICRP as well as with national 22 leading organizations such as the NCRP.
23 They have also had to take into consideration the 24 standards of the of EPA and what DOE is doing, et cetera, and 25 then they have had a host of public comments which they have HERITAGE REPORTING CORPORATION -- (202)628-4888 m
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tried to consider and weave into the document, and all of this
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2 takes time and effort, and-I think the staff has given it that 3
time and effort.
I think the final product is reasonably well 4
written, and to me, it was surprisingly short.
I had t
5 anticipated a document much longer.
I 6
I found also in terms of what was provided us in the 7
way of background for this meeting that it was very helpful to
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8 have the supplementary information provided by the staff in 9
which they gave a careful-statement of each issue that was in, 10
-so to call it contention, and then they gave us summary of 11 comments they have received and then they gave their decision 12 or conclusion on how to handle that particular issue, and
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13 whether you agree with them or not, certainly that puts the 14 issue on the table and puts it out where everyone can see it.
15 And then I have found helpful the section-by-section 16 comparison of the present-Part 20 with the proposed rule as 17 well as with the draft final rule, and then lastly, the j
18 regulatory analysis prepared by the staff at PNL.
PNL was 19 very helpful.
Again, I don't agree with all of it, but it i
20 certainly provided a background that was helpful.
t 21 Having said this, I wanted to outline some of my 1
22 questions and comments, and in introducing my own comments, I 1
23 think that we should at this meeting obviously feel free to i
24 voice complaints or criticisms of anything we see in the O
t 25 report, but I would hope--that's orally, but I would hope that i
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1 in the written comments that we prepare at the end of the j
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meeting during our Executive Session, that we could restrict l
2 3
ourselves to the more important issues and to those things yy 4
where we believe changes, it is essential to make the change, t
5 the change is absolutely necessary.
In other words, I think l
6 those are the comments that would be most helpful to the
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staff, and I would ask all of the Subcommittee members and 8
consultants to keep that thought in mind or those thoughts in r
9 mind as we proceed through the morning.
i 10 Now back to personal observations on the report and t
11 the material prepared for us, and these, I guess I am j
i 12 beginning with the more important ones and dwindling down to 13 the less important ones, but it seemed to me, number one, the I
()
14 regulatory analysis was useful, as I said, but I found certain 15 portions of it questionable, and yet I know they have a r
i 16 certain perhaps guide or formal approach that they have to i
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17 follow, and it seemed to me probably the best part of it was
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18 the list of the qualitative benefits in Section 7, and what 19 troubled me as I read that wa3 if something is wrong, I think 20 it should be corrected regardless of whether there is a t
L 21 cost / benefit justification or what not, and I really--and it's l
22 water over the dam or under the bridge, but I really sometimes i
23 would have liked to have had someone from the NRC staff cone 24 down and justify to me that backfit analysis to comply with 10 25 CFR 50.109 was required in this case.
Maybe they can justify f
HERITAGE REPORTING CORPORATION -- (202)628-4888 r
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it, but that has always given me problems.
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2 And then I noticed in the analyais, and again they 3
have to follow a format, but one' example of the cost cited was
'4 that personnel would have to be trained.
Well, in my opinion, 5
this is not a cost.
This is a benefit.
I mean if we can come 6
up with some new rule or regulation that causes a resurgence 7
in the training and refresher training updating of the people 8
involved with radiation protection throughout the United 9
States, what could be greater than that?
I mean anything that 10 stimulates a renewed interest in rad protection and updated 11 training is clearly in my opinion a benefit.
12 Now among the more contentious issues, of course,
(}
13 will be the committed dese equivalent for long-lived 14 materials.
I have found in reading that, that one place they 15 stated that if only the dose actually occurring during the l
16 year or during a particular year was taken into consideration 17 or was recorded for that year and so forth, that this could be 18 a justification for permitting higher intakes, and I tried to 19 understand how a user would view that approach as a 20 justification for higher intakes, and I presume what they mean 21 is if you were 50, 60 years old and you don't hive 50 more 1
i 22 years to live, in those cases they might do it, but I guess f
23 basicall,v what troubles me, and I'm revealing, of course, my l
24 own biases, is that if a dose has not occurred, I don't see 25 why we should place it in the record as if it had occurred; 1
1 HERITAGE REPORTING CORPORATION -- (202)628-4888
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1 and if the NRC sticks to the proposed position, it is contrary
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2 to NCRP report No. 91, page 19, where they clearly point out 3
the total unacceptibility of that approach, and now the NRC
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4 staff has said in their comments that'really they can't f
5 consider NCRP 91 because it is brand new and it came out after j
I 6
they had become most of their work, but nonetheless, this 4
7 subject has been debated back and forth ad nauseam, and here 8
you have a council chartered by the U.S. Congress to provide i
9 quidancs on this subject to everybody in the United States, 10 and to adopt a position that is contrary, directly in 11 opposition to the recommendations of the NCRP seems to me to a
12 be a very difficult position to take.
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13 Many places--going to another topic, many places 14 within the current report or draft it states that this subject 15 is being debated in a different setting, or that this will be 16.
handled and clearly clarified in a regulatory guide yet to be r
17 developed.
Well, all of these items, I want to see all of 4
18 them listed in a table, so I know precisely what is yet to be 19 done and when.
I will want to see a listing of the topics i
t 20 that are covered in a different setting, the topics that will 21 be covered by regulatory guides, and a schedule on what they 22 anticipate as the timing for follow-through action.
23 Back to NCRP report No. 91, of course, another thing i
24 it recommends is a lifetime dose or dose limit.
That the NRC 25 has not chosen to include, and then they also recommend the l
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1 one millirem per year negligible dose level, and the NRC has I
2L not chosen to include that, although I think in that case they
- 3 indicate once again that the NRC in a different setting is 4
considering this subject of de minimis and below regulatory 2
i 5
concern, and indeed they have an-international symposium t
6 scheduled for Septepber on this. subject, so if that's to be j
7 treated in a different setting, let's clearly spell it out.
8 I noticed in tr.e questions and answers or whatever 1
9 you call the document we received in which the NRC staff r
i 1
10 clearly pointed out how they handled each issue the question i
j 11 was asked or the NRC wrote down the question does the hundred t
l 12 millirem
- year public limit include fallout, the doses from i
13 transportation, et cetera?.And then the answer, unless it is, f
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1 14 my document is missing a page or something, the question was 15 never answered, so I would like to know the answer to that v
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17 Now I notice that discharges to the, to sewers, and I
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18 Mel Carter and I will have to get aff in the corner and decide 1
19 this, they keep talking about discharges to sewage, and Mel 3
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20 and I are old-time sanitary engineers from many years back.
I 21' MR. CARTER:
I misunderstood you.
1 thoughc you 22 said we were going to get in the sswer together!
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23 CHAIRMAN MOELLER:
Well, we probably will, but I l
f 24 would discharge the waste to the sewer.
I never understood l
25 this discharging them to the sewage.
Sewage as I was taught f
I HERITAGE REPORTING CORPORATION -- (202)628-4888
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40 years ago is the combination of a, the sewers and.the v
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2 sewage within them, the entire system, and I think we'are 3
dumping the waste to-the sewers.
4 Anyway, the discharges-to sewers are permitted at 5
an times the concentrations for release to the ambient 6
environment.
I hope I am saying that correctly, and I gather 7
perhaps this has been done, but I didn't see it in what I 8
read, and that is if calculations have been done on the 9
estimates of the doses to sewage treatment plant operators, I 10 am sure someone has done this, but they could have discussed 11 it, and what about the use of the sludge as a fertilizer, and 12 on golf courses and your front lawn and so forth?
And what if
(}
13 someone uses it for a vegetable garden?
I mean that's still 14 done in certain areas of the nation.
15 Okay.
Moving on to more minor or specific points, I 16 was troubled with the definitions.
I just couldn't i
17 read--about every fifth one turned me off, and I wanted to ask i
18 if the definitions were taken from some official approved 19 document?
For example, natural background, in my opinion, 20 natural background is not only the dose from cosmic and 21 terrestrial radiation and internally deposited radioac'iv,e s
22 materials, but it is the dose that arises from thcae 'sourbes 23 in their natural or non-technologically enhanctd set, ting or 24 state, and they never said anything about that.
f(eg
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25 Then they defined radiations and they said beta HERITAGE REPORTING CORPORATION -- (202)628-4888
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particles are radiations, but in the case of electrons, they
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2 have to be fast moving, or high speed.
Well, a beta particle 3
doesn't give me a bit of trouble.
Alpha particle as soon as 4
it finds a couple of electrons and becomes a helium atom gives 5
me no problem at all, but a fast moving alpha particle does.
6 And.then under the definition of uranium fuel cycle, 7
it talked about the conversion of uranium.
I don't know 8
whekher they mean-the purification of the uranium metal, but I 9
don't know how you convert it.
l 10 And then the definition of the whole body.
I don't p.
11 understand the definition of whole body or whole body 12 exposure.
_()
13 Under exemptions to the rule, they included in the 14 classic ones or exemptions not to the rule but exemptions, 15 well, to the dose limits, they included the classic ones of 16 natural background and the purposeful application of radiation 17 in the healing arts, but then now they have added a new one 18 for me--any uses of radiation in medical research are exempt, 19 and I saw no discussion of how that new phrase, how or why 20 that new phrase was incorporated.
21 In the quoted stochastic organ dose limits, they 22 give one number, 50 rem per year, and maybe they are saying 23 well, tha
's as accurate as we can get it, but they also give 24 (the weighting factors and so forth, and if you take the 25 weighting factor for the lung, the dose limit is 40 rem a s
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1 year,-so I didn't understand, unless I am missing something, I I)'
2 didn't understand why they went to a single number of using 50
- 3 and that that was for the stochastic, not the non-stochastic.
4 Next, one thing that has puzzled me for years is why J
5 the excreta from.a patient who has been administered 6
radioactive materials should be given exemption from the 7
release limits, et cetera.
8 Another item in that same regard, and this is one 9
that Jack Shapiro and I have dealt with some years ago quite 10 extensively, and that is--perhaps it is in there and I missed 11 it or perhaps it is covered somewhere else in the regulations, 12 but I saw nothing on limitations of the releasc of a patient 13 on an outpatient basis to whom radiopharmaceuticals had been
(}
14 administered, and I know somewhere in the existing regulations 15 you can't release a patient, you know, until the body content 16 is below X bekirels, et cetera, so I hope it is in there and I 17 simply missed it or it is covered somewhere.
18 Back to the patients that are still in the hospital, 19 I have never understood, as I say, why a hospital can't be 20 required to put in a septic tank that then discharges into the 21 sewer that doesn't need to contaminate the ground in the 22 horpital or just some holding tank that would permit the wasta 23 tc be delayed for a period of time and have all patients who 24 hate been administered radiopharmaceuticals simply use certain 25
- designated toilets in the hospital and hold up that material HERITAGE REPORTING CORPORATION -- (202)628-4888
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for a short period of time.
(_)j.,.2 Going on to ALIs are given for occupational
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3 ingestion.
Now I understand ALIs for occupational inhalation, 4
but I haveLnever understood occupational ALIs for ingestion
.5 because I have always been under the impression that radiation 6
workers drink the same drinking water as the general public.
7 I mean you don't give a radiation worker a separate drinking 8
water supply.
9 Now if the ingestion ALIs are calculated primarily 10 as a basis for developing population ingestion limits, then 11 they have a purpose.
I would like to see that stated, but--if 12 that is the primary reason they were calculated.
I have no
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13 problem with the numbers.
14 I do wonder, though, are these numbers based upon 15 the calculations by the people at ORNL?
If they are done at 16 Oak Ridge, I am happy.
I say that because the ICRP, unless my 17 memory is incorrect, the ICRP has yet to public ALIs for the 18 general public.
In fact, the last time I looked into it, they 19 said there were so many considerations that had to be brought 20 to bear in translating an occupational ALI, either ingestion 21 or inhalation, over to the general public that they weren't 22 ready to do it, and now the NRC has done it.
More power to l
23 them if it is based upon, as I say, the computational group at 24 ORNL who as I recall do the same, who provide the same numbers 25 to the ICRP, then we are in great shape, and more power to the r
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NRC.
)
2 I noticed to designate a very high radiation area, 3
they say 500 rad per hour.
Well, they talked about neutrons a 4-lot before that, so for neutrons, then is it 5,000 rem per 5
hour?
I was curious.
6 I also found it curious that for present licensees, 7
they are supposed to apply the dose limits for the existing 8
ten CFR 20, but use ICRP 30 for tneir calculational 9
methodology.
This is an interesting combination of old and 10 new within one setting, and I found that intriguing.
11 The Q value for neutrons--I am about to wind 12 down--the Q value for neutrons, they pointed out there is not y()
13 a consensus on this, and so they stuck with the quality value 14 of ten.
I was curious to ask what did the NCRP have to say 15 about this.
I don't remember, but I would, I would think it 16 should have been in there somewhere.
17 And then lastly, they have avoided the words 18 collective effective dose equivalent.
They said they had I 19 guess defined it at one time but withdrew it from the latest 20 document, and I guess if it is not needed, then you don't need 21 to put it in, but I was surprised that that gave them such 22 problems.
23 Well, having said more than I intended to say, let 24 me ask Charlie, do you have any comments or thoughts?
- Jack, 25 do you have any.
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MR. SHAPIRO:
Not at this point.
f3
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CHAIRMAN MOELLER:
I know you will have plenty 3
later.
Mel?
4 MR. CARTER:
Let me mention a couple of things that 5
are, comment on them.
One, of course, I am always amazed that
-6 it takes so long to produce something like this.
Like you 7
say, certainly an awful lot of effort and work goes into it.
8 If you think of the fact that the ICRP publication that 9
triggered all of this if you want to use that word was ICRP 26 10 and that was published in 1977, here we are some 11 years 11 later contending with the issue in the United States on a 12 national basis.
(}
13 The other thing, in the business update of the CFR 14 20, you would like the fact that in general, at least, it is 15 compatible with international, national organizations and also 16 some of the federal agencies.
The other thing, they included 17 some specifics, which I think is good, in one, the exposure i
f i
18 for the embryo fetus, and the other is exposure for members of i
19 the population.
In fact, that part of NCRP 91, they managed i
20 to cover, namely, the dose to members of the public.
21 One thing that I'm quite interested in now is i
l 22 whether or not this is, these regulations are going to be 23 compatible with 40 CFR 90, and I would be very much interested 24 in some discussion of the uranium fuel cycle of the EPA 25 because I don't see it mentioned in any extent in the one I HERITAGE REPORTING CORPORATION -- (202)628-4888
16 1
did.
s.
2 The other thing that intrigues me, some.of the cost
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3 data that were used to generate some of the costs involved, 4
namely, for urinalysis for implication for tritium and 5
phosphorus 32, something like $20.00.
I would be very much 6
interested on a personal basis knowing what labs charge 7
because I think I could use them from time to time.
8 That's all.
9 CHAIRMAN MOELLER:
Okay.
Thank you.
Well, now we 10 will proceed aith the meeting, proceed with the meeting, and 11 we will call upon the NRC for their opening presentation.
I 12 understand that an introduction and overview will be presented
()
13 by Bill Morris.
14 MR. MORRIS:
I am Bill Morris, Director of the 15 Regulatory Division of Regulatory Applications in the Office 16 of Research.
17 What I wanted to tell you about as a introductory 18 remarks today was something of the process that we have 19 followed in the arriving at where we are today in developing 20 this proposed revision of 10 CFR Part 20.
21 It was about a year ago that the EDO directed the 22 staff to proceed as rapidly as it could to develop a revision 23 of 10 CFR Part 20 that would endorse essentially the elements 24 of the new federal guidance, and we knew that was quite a 25 large undertaking, and because of the previous publication of HERITAGE REPORTING CORPORATION -- (202)628-4888
17 1
a proposed revision of this and the response which amounted to r')
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2 some 800 comment letters, we knew we had a lot to do, and the 3
mechanism that was set up to do that involved an interoffice 4
working group that involved members of the various 5
participating offices, and in addition, a consultant.
6 I wanted to introduce those members today because in' 7
addition to the efforts of Hal Peterson, who is the task 8
leader who has done a lot of the writing work, these gentlemen 9
have provided in valuable assistance and have made it possible 10 to get an early approach to a consensus between the various 11 offices.
12 John Buchanan is the representative from NRR on the
)
13 working group, and Don Cool from NMSS, and Walt Cool, who had 14 tried to retire, was called back to service because we needed 15 his expertise to move this rulemaking forward, and he has been 16 kind enough to help us out through this process, and they have 17 all worked with Hal Peterson to come up with the revision that l
18 you will be reviewing today.
And as I say, I apprecieta all l
19 of their work, and make note of that here today.
20 In addition to their efforts, there has been a 21 steering committee consisting of other members of management 22 in the various offices, and OGC and the Office of State
-23 Programs.
Richard Cunningham of the NHSS, Frank Cogile of 24 NRR, myself from Research, Joanna Becker from the Office of 25 the General Counsel, and Mr. Newsbaumer of the Office of State HERITAGE REPORTING CORPORATION -- (202)628-4888
18 1
Programs have participated in a steering group to give
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2 feedback to this working group as they have developed various 3
revisions to part of this document.
4 So what we have tried to do in this process is to 5
facilitate and accelerate the consensus building process 6
within the various offices, and I believe it is, it has worked 7
well.
I don't know how we could have gotten here at this time 8
unless we had used that mechanism because it has made things I
9 move faster.
And of course, there are many controversial 10 issues that have been grappled with here.
The decisions that 11 have been made in developing this proposed draft have been 12 difficult and we have spent a lot of hours debating just how 13 we should proceed.
And sometimes there is a judgment call 14 involved and your views on this are still, of course, valuable 15 to us because this is, this stage is a proposed document that 16 we would now move forward through the process--the ACRS 17 review, the CRGR review, send it to the EDO with those 18 comments incorporated as well as we can, and move it up to the 19 Commission as a proposed rule change.
So your efforts to 20 review this document are appreciated.
I know it is a lot of 21 material to send to you to look at, but we have, nonetheless 22 have to move forward.
23 With those remarks, I would like to turn it over to 24 Hal Peterson who will carry you through the detailed analysis 25 of this new, this new Part 20.
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Thank you.
('/)
2 CHAIRMAN MOELLER:
Well, thank you, Bill.
I m
3 particularly appreciate your comments and and your naming the 4
staff members who have worked hard to prepare this document.
5 Too offen we receive an NRC report, a NUREG, and it is just 6
authorless.
You never know who went into it.
Unfortunately, 7
10 CFR 20 as published will be authorless other than a small 8
paragraph near the end to call Hal Peterson if you have 9
questions and so forth, but I think this is good to give the 10 recognition to the people who have done the hard work.
Thank 11 you for doing that.
12 MR. PETERSON:
Thank you, Dave.
I might start
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13 perhaps--I know Dr. Carter mentioned the time it takes to do 14 this.
Of course, this effort actually started back in 1978 15 following receipt of the 1977 ICRP 26 report with a staff 16 group that got together and started looking at how we might 17 implement that, those recommendations into the NRC rules and 18 regulations.
19 That group e'entually produced a notice of proposed, 20 advanced notice of proposed rulemaking that was published in 21 1980, and solicited public input on how to do this, and that 22 it took a couple of years.
The end of 1985 finally we came 23 out with the proposed rule after a lot of staff effort and a 24 lot of contact with various groups, including the rather 25 uncommon practice of giving out drafts during the development HERITAGE REPORTING CORPORATION -- (202)628-4888
20 1
of a rule for comments, so that that was a long process, and
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2 it has been about two years since, two and a half years since 3
the proposed rule was released, and we received about 800 and, 4
a little over 800 comments on that, and it took quite a while 5
to whittle those down and then to come up with a rule.
6 The other problem is, as you indicated earlier, Dr.
7 Moeller, there is a rather large package that goes with this, i
8 and the problem we have is that although we tried a little 9
parallel development, you really need almost the final rule 10 before you can develop all the other supporting material, so 11 that's one of the reasons I think for the length of time it 12 takes to get where we are.
13 I think your suggestion about putting a list in the 14 statement of considerations about the topics that are 15 unresolved and will be resolved later, and those that are a 16 list of proposed regulatory guides which we do have a 17 preliminary one could be very well inserted in the statement, 18 and I think we will do so.
l 19 The definition of natural background I know Dr.
20 Moeller mentioned.
We agonized over that.
Most of the 21 definitions are patterned after the formal terms of ICRP I 22 think it is 46 or is it 40?
One of the two documents; there l
l 23 is an ICRP definition.
The trouble is that most of the l
l 24 official ICRP texts we felt was a little too concise, a little
(
25 too technical for the audience we intended to reach, so we l
HERITAGE REPORTING CORPORATION -- (202)628-4888 L
21 1
I l
i tried to simplify the text in some cases there to get around f: ()
2 the detailed technical nomenclature.
3 Dr. Hoeller indicated the regulations on patient 4
release.
I am happy to say we do have them.
They are in Part 5
35 of the medical, medical rule.
They are not in 20.
In 6
terms of the calculations of the ALIs and the DACs for members 7
of the public, those are based on the Oak Ridge calculations 8
ICRP 30, but Oak Ridge did not do those.
Walt Cool basically 9
did those.
Those numbers are somewhat different than the ICRP 10 would do for the members of the public.
I think we explained 11 it in the statement, but basically, the ICRP vould apply a 12 factor of ten to the dose limits for occupational workers and 13 bring them down to members of the public to the 500.
14 In some cases when you do this, for the DACs, many 15 of the occupational DACs are based on this non-stochastic 16 organ dose limit.
That is the 50 rem dose to any organ.
17 Now clearly we felt if 50 rem is a threshold, which 18 it is supposed to be, for the worker, then 50 rem is also a 19 threshold for the non-worker, so that all of the public 20 DACs--drive to air concentrations--and the water 21 concentrations, are based on the stochastic or the cancer 22 risk, do not include this capping dose because there is no 23 need.
They never get up to 50 rem, so in that case they are 24 different from the, what the ICRP would do.
25 They are also I should point out, and I think the HERITAGE REPORTING CORPORATION -- (202)628-4888
(
22 1
statement does, that they are based on 50 millirem.per year
./^/
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2 doses, not the hundred reference level, and there is a factor 3
of two in there to take into account essentially age 4
dependence for the population.
It is a very crude factor, but 5
this is part of the problem I think.
Dr. Moeller indicated t
6 that what Oak Ridge referred to in doing the general public is 7
that you have a set of age groups and the intake,to dose 8
conversion factors are not the same.
9 In terms of the calculation of Q, the NCRP value I 10 did check in 91, is 20, and we are not at this time adopting 11 that value primarily on the advice that we know that the ICRP 12 is going to be looking at the whole issue of quality factors,
()
13 particularly as to what the proper reference radiation might 14 be if you are using an old relative biological effectiveness 5
15 type of approach to Q, and we are trying to hold off until 16 they get that straightened out.
17 There is a probler, as we indicate, with some of the 18 neutron Q estimates that are based on our BE in that they are 19 based on using cobalt 60.
That is the reference radiation, 20 and according to the ICRU at this point, cobalt 60 has a Q of 21 a half compared to the 250 kev X-rays.
There is some 22 discrepancies there.
One thing we definitely don't want to do 23 is to get into assigning different Qs as a function of photon 24 energy that is going to require lot lower gamma spectometry in 25 the field.
HERITAGE REPORTING CORPORATION -- (202)628-4888
V 23 1
I think I have covered most of the questions.
Oh,
[)-
2,
Dr. Carter's questions, 40 CFR 190 is in there,'but it is ss 3
hidden.
We didn't refer to it by name.
There is a section 4
'2304D, which is_on page 29 of the regulations, that says in 5
addition to complying--this is in the limits for the 6
public--in addition to complying with the above, licensees 7
subject to EPA generally applicable environmental standards 8
shall comply with those standards, and that's the 40 CFR 190 9
incorporated by reference across reference.
10 Okay.
Has everybody got one of the handouts?
There 11 are a few I see still sitting on the first chair on the far 12 side of the, that side of the room.
I don't want to say left 13 or right because we are facing different ways.
)
14 I would like to do something.
I would like to start 15 off with page 2 if we might.
There has been a good deal of 16 discussion as to whether this revision of Part 20 was really 17 necessary.
And even among the NRC staff there was some views 18 if it ain't broken, don't fix it.
I think two is a summary of 19 the problems with the current Part 20.
The first of all is 20 that the basic numbers that we used for the NPCs and the 21 intake control are really based upon numbers that were set r
22 first in 1955 and then in, finalized in 1959, so they are 23 almost 30 years old.
24 Secondly, the present Part 20 interestingly enough 25 does not have explicit dose limit for annual dose limit for HERITAGE REPORTING CORPORATION -- (202)628-4888
24 l'
protection of the public.
The section that has tho'500 g(.)
2 millirem limit say if a licensee submits a number like that, 3
the Commission is apt to accept it.
The real limits fall into 4-either an hourly limit from unrestricted areas of 2 millire.n 5
per hour, or a hundred millirem per week, and then the 6
concentration limits which are probably the one that is 7
controlled most effectively for nuclear installations off 8
site, are in 20 105B really the controlling facto.m, so that 9
there is no explicit limit.
Dr. Carter mentioned the embryo 10 fetus protection.
There is no explicit limit for the embryo 11 fetus.
12 Lastly, in terms of the updating, the proposed, the
()
13 present rule, of course, is not compatible with the 1977 ICRP 14 26 revision.
It does not use things like effective dose 15 equivalent.
16 In 1987, the EPA published or the President approved 17 guidance that was prepared by an EPA task force on revised 18 occupational guidance, and that is not consistent with the 19 present Psrt 20, and also the present Part 20 has been amended 20 over 90 times in a piecemeal fashion, and could use some help 21 with organization.
For example, the entire section dealing 22 with regulation of high energy or high-level irradiators is 23 listed in a section that is actually posting and all the 24 regulations fall under the sign and which there is one--that 25 reminds me of one question I didn't answer, the question about i
HERITAGE REPORTING CORPORATION -- (202)628-4888
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25 l'
the neutron and how that was written with the rad.
That has a l
)
2 footnote.
That section has a footnote that says it applies 3
only to high dose gamma irradiators.
The neutron question 4
doesn't arise.
5 CHAIRMAN MOELLER:
Fine.
Thank_you.
6 MR. PETERSON:
I will throw that in while I think of 7
it.
8 In terms of--now we can go back to the first page.
9 In terms of the new Part 20, what we hope to do is update the 10 scientific basis for all the dose and concentration limits, 11 provide explicit limit for both the public and the embryo 12 fetus to show protection of those individuals, adopt the ICRP
()
13 26 risk based dose limitation system, implement the federal 14 guidance, and provide for a better organization of 10 CFR 20 15 than we did in the past.
16 MR. CARTER:
Could I ask you a question?
17 MR. PETERSON:
Certainly.
18 MR. CARTER:
Assuming this all gets approved and 19 becomes effective in '91 or whenever the effective date, 20 proposed date would be, you still anticipate that you will 21 amend CFR 20 between now and that affective date?
22 MR. PETERSON:
There are two sets of amendments I am 23 aware of that would probably affect it.
One is a change in 24 the, certain incident reporting requirements.
That has just 25 being proposed at this stage.
HERITAGE REPORTING CORPORATION -- (202)628-4888
26 1
The other one is the so-called de minimus or below
- ( ).
2 regulatory concern level, which is on a parallel track to 3
this, although probably about a year or two behind us, so 4
there should be a policy out later this fall I think, and then 5
from that there will be a rule change, so yes. I do think that 6
this will be amended as we go along, and also many of the 7
scientific issues we hope will be resolved such as the neutron 8
Q in time for us to put in, the final in before the effective 9
rule becomes in place.
10 Okay.
If we could go then to Table 3, or page 3, 11 most of the benefit of the Part 20 revision fall mainly on the 12 NRC itself.
It has some side benefits to the industry.
13 Basically for us, it provides the conformance with the federal
{
14 guidance with respect to NRC policy.
It will provide 15 conformance with most, but as Dr. Moeller indicated, not all 16 of the NCRP's recent recommendations.
17 The adoption of ICRP 26 approach should provide a 18 good deal of comparability with the standards of other 19 countries and those of international organizations such as the 20 IAEA, the CEC, and the EECDNEA, the Nuclear Energy Agency.
21 The risk based approach we think will provide a better i
22 understanding of radiation protection goals.
f 23 We also are in the process of updating the metabolic 24 and dosimetric parameters to incorporate the new 25 gastrointestinal uptake for the, mainly for the numbers that l
HERITAGE REFORTING CORPORATION -- (202)628-4888 t
27 1
were published in ICRP report No. 48, and we have gotten those p- (,)
2 changes from Oak Ridge presently modifying the numbers in-the 3
table.
4 Lastly, we think the new approach, the new Part 20.
5 provides more consistency, not total consistency, but in the 6
work consistency in the handling of internal and external 7
doses.
There was a tendency I think in the old rule that an
'8 external rem is okay, but an internal rem is not so okay.
We 9
are allowing that they should be treated more equal.
A rem is 10 a rem, so that in some cases, we have lessened protection for 11 internal radionuclides in one case, plant special exposures.
12 We have changed that to permit an internal burden to be 13 assessed against an external dose, so in other words, if a 14 licensee could keep the total dose lower by allowing some 15 people to go into an airborne area without a respirator for a 16 short job, then this might be permitted as an example of ALARA 17 if the total dose were to be icwer rather than just minimizing 18 the internal dose.
19 Now the Part 20 revision has considerable cost 20 associated with its implementation.
First, there are a whole 21 set of new quantities, and I am sure you have noticed the 22 extensive tables of definitions which are far, far more than 23 in the present rule, and the system of dose limitation, the 24 concept of effective dose, for example, introduces greater 25 complexity in radiation protection practice.
HERITAGE REPORTING CORPORATION -- (202)628-4888
= _. _
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28 1
There is a change in the fundamental approach to I
2 both dose evaluation and recording that is necessitated by 3
this system.
This might be likened to the fellow who went to 4
his dentist and the dentist said Fred, I have got some good 5
news and some bad news for you.
He said your good news is 6
your teeth are okay.
The guy said what is the bad news?
He 7
says your gums have got to come out, and this is in a way part 8
of the Part 20 problem if you will, the implementation cost, 9
because we are really saying to the industry the system needs 10 to be changed.
It is the gums that we are changing, not the 11 final level of protection, and that has to do with a lot of 12 implementation costs of the rule.
()
13 There is also a reduction.
Most of the drive air 14 concentrations go up, interestingly enough; 68 percent go up, 15 and this has to do with the fact that the old concentration 16 limits were based primarily on organ dose limits of 15 and 30 17 rem where in some cases, the new system, a higher dose is 18 allowed either with this stochastic number--I think for bone, 19 for example, it goes to 42 rem, but also when you use that 20 non-stochastic cap, then you get an organ dose limit that is 21 50 rem, and in many cases, these are the limiting factors so 22 that the DAC does generally go up somewhat.
23 MR. SHAPIRO:
For the public, it goes down?
24 MR. PETERSON:
For the public--if you want, I will 25 show you something later--it goes every which way for the HERITAGE REPORTING CORPORATION -- (202)628-4888
29 1
public because there is no consistent thing because you have, (o/
2 that there is an upward effect and then there is downward s
3 effect with the dose limit.
I will mention that at the end if 4
you.can hold on.
5 But anyway, there are some changes to concentration 6
limits that go down, and two of them, one of them is thorium 7
232, which drops by a factor of 60.
I don't know exactly what 8
effect that may have on anybody practicing--thorium, thorium 9
mantles are alco made outside this ccuntry.
In the future 10 that's a possibility.
11 The other thing is the reduction in natural uranium 12 and uranium 238 by about a factor of five for insoluble
()
13 uranium.
This has some severe implications--I know Mr.
14 Stansbury is here from GE Wilmington--to fuel fabrication 15 plants because it means that plants that were operating at 15 16 percent, say 15 to 20 percent of the dose limit one day, are 17 going to be operating at 75 percent to a hundred percent of 18 the dose limit the next day when this comes into effect, and 19 that's one of the main true costs if you will, control costs, i
20 associated with the rule.
21 Another cost is the requirement to notify workers 22 annually of their dose.
This has a present worth of about $10 l
23 million.
The present Part 19 has a provision that whenever a 24 bioassay or other special test is made, the worker should be 25 notified, and that upon request, a worker may be notified at HERITAGE REPORTING CORPORATION -- (202)628-4888
30
'1 least annually of his dose or should be notified annually, at D
s_/
2 least annually of his dose.
3 of course, the way we would implement this--this is 4
part of the federal guidance.
The way we implement this is to 5
remove the words "upon request."
As I said, that has a, about 6
a $10 million overall price tag.
7 General changes from the rule, we have--from the 8
proposed rule, we have generally drafted, redrafted several 9
sections to improve the clarity of the presentation.
We have 10 removed a lot of non-regulatory tutorial information that was 11 in the rule.
Some of that has been incorporated into the 12 statement of considerations, and lastly, we have reorganized
[}
13 and revised the definitions to stand alone.
For one thing, 14 they used to be grouped by groups.
They were area terms and 15 so forth.
16 And let's get into some of the more details.
The 17 changes to update the present and proposed rules since the 18 proposed rule was issued in the beginning of
'86, one is to 19 incorporate the final provisions of the 1987 federal guidance.
20 The staff, members of the staff had been on the EPA task force 21 that prepared the federal guidance, so generally the rules 22 have gone pretty well parallel, but there were some final 23 finetuning, that notification of workers is being one of them.
24 That occurred with the final version of the federal guidance, 25 and we incorporated those portions into the rule.
HERITAGE REPORTIllG CORPORATIOli -- (202)628-4888
1 31 1
Secondly, we have revised the dose limit for members
) _
of the public from 500 millirem to 100 millirem.
There was a 2
3 reference level in the prior rule that was 100 millirem.
Most 4
of the public comment on that indicated their belief that you 5
might as well make it a limit because you have got a reporting 6
requirement if you exceed it, and a record keeping requirement 7
anyway.
There is no difference between then your reference 8
level and the limit.
9 The real reason we made it a limit is because the 10 ICRP has clarified what they thought the limit was.
They have 11 clarified that the 500 is for exceptional use, and the 100 is 12 for a long-term average.
Now we can't do, implement a
(}
13 long-term average limit on a person in the general public.
14 There is no, there are no controls over a member of the 15 general public like you have over a worker to do a long-term 16 average.
You don't if this guy is going to move out of his 17 house tomorrow and go next to another plant or not.
So what 18 we do, of course, is do it on annual bases; 500 is still in 19 the rule as a limit that is available upon request by 20 licensees.
21 Primarily the intent of that was the fact that there 22 are so many teletherapy units that are designed, that were 23 designed with the shielding to handle dose rates of 500 MR per 24 year as the limit that if we didn't have a clause like that we 25 would require reshielding every unit in the country HERITAGE REPORTIllG CORPORATION -- (202)628-4888
J 32 1
essentially to, to make sure they could meet the hundred, so
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2 that's, but that's available.
They have to show the need for 3
that.
4 MR. CARTER:
What is the rationale for getting away 5
from the old usage, for example, of having a number and then 6
having a suitable average sample of the population?
The 7
factor of three used to be 500 and 170 in essence based on 8
that.
9 MR. PETERSON:
The federal guidance, of course, had 10 that, the concept in it.
The old Part 20 also reflected that.
11 We have gotten away from that primarily because the suitable 12 sample, we really regulate on an individual.
It is not really
()
13 done on a suitable sample, so it is so to speak--we have to 14 have a defined location when we evaluate somebody off site so 15 it is hard to say that it is a suitable, that it is a sample, 16 and the other thing is I would really love if you ever come 17 across the derivation of that factor of three--I have never 18 been able to come up with, you know, the numbers that would 19 give me a factor of three for that difference.
20 HR. CARTER:
It is a statistical number.
21 CHAIRMAN MOELLER:
Back on teletherapy units that 22 may, the owners may apply for an exemption to get up to 500.
23 Is this to protect clerical personnel in the hospital, or is 24 it to prot ct people living next door?
l 25 MR. PETERSON:
Could be a little bit of both really I
HERITAGE REPORTING CORPORATION -- (202)628-4888
33 1.
the way that.the limits apply.
It would be the limit, of
)
2 course, at the end of the restricted area which could account
.s 3
for both in-hospital use, waiting rooms and so forth.
4 CHAIRMAN MOELLER:
Okay.
How many of those are 5
there?
Is it thousands or hundreds?
6 MR. PETERSON:
Certainly, Don, hundreds?
7 MR. DON COOL:
Donald Cool; I am with the Office of 8
Nuclear Material Safety and Safeguards--I am not sure I can 9
give you a precise number, and I am not sure that we should 10 even be focusing per se on teletherapy units, installed unit.
11 I would like to remind the group perhaps the 12 provision that we have laid out tor 500 millirem upon
(}
13 application of the Commission has several constraints to it, 14 one of which is they have to inform the Commission, provide an 15 amount of time under which this exemption is to apply.
It is 16 not intended to be a carte blanche, it is not per se intended 17 in any one particular group, although units such as 18 teletherapy units which are designed in a particular way may 19 well be a group which benefits from this, and it was not 20 intended, I think Mr. Peterson will agree, this is not 21 intended to be a carte blanche now type of situation, but 22 rather this incorporates ICRP view of the, allowing the 500 23 millirem type of level over shorter durations.
There is more 24 specific information available.
25 That would be beyond--your question was I suspect i
HERITAGE REPORTING CORPORATION -- (202)628-4888
34 1
there is maybe several hundred to the thousand type range.
I O
(_/
2 do not have a good feel for how many units would actually have 3
trouble with that particular limit, and I should also point 4
out that there are still the provisions of dose rate per hour 5
which are still incorporated in the text of the rule.
A lot 6
of the units operate under those provisions and continue to do 7
so.
8 MR. PETERSON:
I think Dr. Cool's point is well 9
taken.
That provision is open to everybody.
I just use the 10 teletherapy as an example of an obvious case where there might 11 be use of it.
12 CHAIRMAN MOELLER:
On the hundred millirem
()
13 long-term, back to the question I asked or expressed in my 14 opening remerks, does it include fallout and transportation?
15 MR. PETERSON:
No.
The only thing we have included 16 in the hundred is the direct activity, the effluent and direct 17 radiation from the licensee's activity itself.
That's the 18 only thing we feel we could hold him to.
19 CHAIRMAN MOELLER:
Okay.
If there are several i
20 facilities impacting on a single population group, then how do 21 you assure that the population doesn't get more than a 22 hundred?
23 MR. PETERSON:
The several facilities is primarily j
24 as I could see something that is more likely to occur with the i
i 25 nuclear field with reactors across--of course, the limit for l
HERITAGE REPORTING CORPORATION -- (202)628-4888
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35 1
the public there is--
.,,,)
2 CHAIRMAN MOELLER:
Appendix I.
t 3
MR. PETERSON:
It is EPA, so it is 25, so the 4
multiple would have to be below a hundred in any cas e.
In 5
fact, if they are very close and do substantially cor:t!. ibute, 6
then they have got to total to 25 the way the EPA rulo is 7
written.
8 CHAIRMAN MOELLER:
Well then, how could the hundred 9
ever apply if EPA wants 25?
10 MR. PETERSON:
Okay.
The hundred might apply--the 11 problem we get into is that there are diversity of standards.
12 The EPA has some under generally applicable standards that 13 covers the fuel cycle, but for example, it does not cover
,/ }
14 radon, doses from radon emissions from uranium mill tailings.
15 It also has Clean Air Act, which covers airborne effluent from 16 all facilities at least at this point except the uranium fuel 17 cycle facilities at 25.
It does not have any standard that 18 covers liquid effluent from those facilities that are not in 19 the uranium fuel cycle, and so that that's one aiea where the l
20 hundred would be the controlling number offhand.
1 21 MR, CARTER:
Their fuel cycle now eliminated or 22 didn't consider several things, including mining, certainly 23 the milling aspects, and I believe transportation and waste 24 disposal.
25 MR. PETERSON:
They said they were going to do and HERITAGE REPORTING CORPORATION -- (202)628-4888
..~
36 1
have done waste disposal.
Later standards did not include
()
2 transportation, and the milling and mining, that was forced 3
because the generally applicable standards are developed under 4
the Atomic Energy Act authorities.
They can't consider ti.e 5
mining because the AEA doesn't, the' Atomic Energy Act doesn't 6
cover mining.
So that has to---
7 CHAIRMAN MOELLER:
I/essume OSHA or someone covered 8
mining?
You are talking primarily occupational?
9 MR. PETERSON:
MSHA, the Mining Safety and Health 10 Administration.
11 CHAIRMAN MOELLER:
You are correct.
12 MR. PETERSON:
And the uranium mil standards under
()
13 the Clean Air Act have covered on emissions from the mine, so 14 the--but there are these various pieces and they don't all 15 quite, quite fit together very neatly, but that's, the hundred 16 is not to be, really we have not claimed any great dose 17 savings to the members of the public from going from 500 to e 18 hundred simply because mgat of them are regulated at 25 either 19 by the Clean Air Act or 40 CFR 1 or another standard.
20 MR. CARTUR:' }*ouhavegot to be a little careful.
21 Dade menticaed the OSHA, for example, but you know, if you 22 think about it, in '87 when we went towards ICRP or moved in 23 that d4rection, it was done on occupational basis, but it was l
24 done by EPA, so this is our Environmental Protection Agency 25 which you normally wouldn't think would regulate occupational HERITAGE REPORTING CORPORATION -- (202)628-4888
r' 37 1
exposure.
g (m) 42 MR. PETERSON:
Of course, it is done under the old I
3 FTC.
[4 MR. CARTER:
Advice to the President; I am curious
.l'
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as Dade is about the impact now or how this is going to work 5
6 if you take a severe example and relate what you have got now
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in proposed 10 CFR 20 with 40 CFR 10 of EPA, if you had a case
- 1 ~
8 where a reactor, f<r example, was, or some nuclear fuel 9
facility, heaven help us, if they were putting out above the 10 limit.
Now which limit is going to control this thing?
I 11 presume the EPA limit.
e r
12 MR. PETERSON:
EPA limit is in fact incorporated
()
13 into 2301 as 2301D, which just says that licensees subject to 14 EPA generally applicable environmental atandards shall comply 15 with those standards which is, makes it enforcible under, for 16 us to enforce the EPA limit without physically putting the 17 number in, and of course, the way we have werked in the 18 proposed rule, we have left it that that cavers not only 40 19 CFR 190, but also the high-level waste standard in 191 t
20 uranium mil standard in 129 and when they come to the lowe; 21 level waste standard in 193, so--
22 MR. CARTER:
If a theoretical individual were 23 exposed to tour fuel cycler, four fuel cycle facilities, and I l
24 suppose that's a potential, then it might be touch and go l
25 whether it would be 49 CFR 190 that would control or whether l
HERITAGE REPORTING CORPORATION -- (202)628-4888
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38 1
-it would be--
][
2 MR. PETERSON:
Not because the 190 controls; that i)
I I J
the_ total dose to the individual from the uranium _ fuel cycle.
,. c 4-MR. CARTER:
You have got--104 of these)might give L
1 S
you a hundred_also.
4
/
6-MR. PETERSON:
Then-we will hit them twice 7
basically.
The EPA one is the controlling one.
It is, there 8
are very, very few sites that we know certainly in the nuclear 9
fuel 4rdustry that have that kind of overlap.
There is 10 several reactor sites.
I can reel off just a few that have 11 different companies operating there.
Now the EPA rule is 12 precise.
It doesn't matter if they have three reactors in one
()
13 company at a site.
It is also for total site in contrast to 14 say Appendi-which is a per reactor number, but you can get 15 very close with three reactors.
16 HR. CARTER:
Well, some of the Appendix I also deals 17 with a site.
It is reactors in general, but it also deals 18 with site and some of it gets fairly fuzzy I might add.
19 MR. PETERSON:
Yes.
The external dose limits at a 20 pcin : one other change in updating that was actually, we did 21 it and then rules and records caught up with us, is that we 22 have now changed the record keeping requirements so that 23 electronic records are now permissible to keep files and 24 we hope to exchange information with the NRC on, for some of>
.O 8
25 the larger licensees.
HERITAGE REPORTING CORPORATION -- (202)628-4888
39 1
Now we heve made--those were changes to reduce, to
()
2 update the-rules.
We have made'some changes to reduce the 3 -
implementation costs.
We have eliminated requirements for 4
detailed documentation of ALARA actions that were called out p.
5 in the proposed. rule.
This is the, was one of the largest 6
single-costs associated with'the proposed-rule.
Licensees did 7
not like it one' iota, and we generally felt that retaining.it-8 would be counterproductive to being, te keeping ALARA efforts 9
in because it, it kind of puts a burden on the licensee then 10 to document every single thing he does to be ALARA where if he 11 only does three things and not four, then there is one less 12 thing to write up.
13 And associated with that, as I mentioned, is a large
(}
14 cost.
We have al o reduced the requirement for surveying 15 packages upon receipt to two categories.
There was a lot of 16 hew and cry about requiring every package that was received to 17 be surveyed, and this now comes down to either they are 18 visibly marked as containing radioactive materials according 19 to DOT.
If they are not, they are probably such small 20 quantity it is not particularly important that they be 21 monitored, or that their packages, regardless of whether they 22 are marked or not, are leaking or damaged or some other reason 23 that they should be surveyed.
24 HR. SHAPIRO:
Are you requiring both external and 25 wipe surveys even though the package may just contain tritium HERITAGE REPORTING CORPORATION -- (202)628-4888
T' 40
~1 or carbon 14?
Is that true?
' O).
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2 MR. PETERSON:
That is true.
Of course, in some 3
cases,1 carbon 14, tritium, the wipe survey may'be probably the 4
preferable one.
You may be able to liquid scintillation count 5
the wipe as external but I don't they would be much use.
6 MR. SHAPIRO:
Lot of busy work; I know they do a lot 7
of busy work now, and I will go into this a little later, from 8
the point of view of our own institution, but taking care of 9
packages, when you handle a large level, it could be fairly 10 onerous.
Some of the requirements and the way the inspectors 11 enforce these things also can be very onerous for the 12 institute.
( f 13 MR. PETERSON:
he try to make it to two fairly 14 identified cases--the one where the package is clearly marked 15 as radioactive, and there is a problem.
One of the things, of 16 course, we are looking for is something that has to do 17 possibly with some of the isotope generators, the shield plug, 18 sufficient, couple of, several millicuries of activity in the 19 package, and the shield plug has become unstuck or something, 20 so there is now a beam of radiation coming out.
That's one of 21 the things we are worried about.
Of course, that should be 22 picked up upon shipment, but also here, but we have changes.
23 Not all packages; we have tried to cut down the impact some 24 there.
25 CHAIRMAN MOELLER:
To help me now, this is a change HERITAGE REPORTING CORPORATION -- (202)628-4838
41 1
between a previousy version and the latest.
How does it
()
2 compare to existing 10 CFR 20?
What surveys of packages are 3
required?
4 MR. PETERSON:
I think the existing and the proposed 5
are the same.
6 CHAIRMAN MOELLER:
Okay.
7 MR. PETERSON:
No?
8 MR. WALTER COOL:
I am now consulting for NRC--the 9
existing rule has a number of specific cases where small 10 quantities of tritium, carbon and sulfur--I don't--maybe 11 others--are not required to be surveyed upon receipt. -They 12 are exempt.
The proposed rule would have required surveying
()
13 every package.
This rule now ties it in with DOT and in fact 14 the quantities are larger in almost every case, so there will 15 be relief from the survey requirements for a lot of packages.
16 CHAIRMAN MOELLER:
Thank you.
17 MR. PETERSON:
Thank you.
The last of the changes 18 to reduce the implementation costs is that we have eliminated 19 the furnishing of termination reports.
This is usually upon 20 an individual leaving the employ of a company, the company had 21 to give NRC a termination report.
This is fairly onerous to 22.
people in the nuclear power industry because a lot of 23 temporary workers do move around and every time they come
- 2. 4 through the plant, there is a termination report, every time l-25 they leave, so what we have done here--this is to have been HERITAGE REPORTING CORPORATION -- (202)628-4888
42 1
changed--essentially we are doing a quid pro quo with the
)
2
. industry in that we are dropping the requirements for an 3
annual statistical report which used to give numbers of people 4
in dose ranges, and just saying give us the numbers for 5
individual monitoring ports for the same group of licensees 6
that had to do the statistical report and the termination 7
report which is, are those in, well, they are listed on page 8
8, No.
2.
They are seven, seven categories, power reactors.
9 They are all essentially the large source users, the onen 10 where we expect some identifiable exposure.
11 HR. SHAPIRO:
I wonder when you have all these 12 regulations--I don't know if this is the place to mention it
(}
13 or not--presumably they apply to workers who are required to 14 be monitored and registered because they are going to receive 15 a certain percentage of your dose limits, 10 percent of your 16 dose limits.
17 on the other hand, our own institution, many others, 18 register almost everybody in a program whether it is for legal 19 reasons or better control and so forth.
20 Now to what extent do you or do you not require that 21 these other workers conform with all your record keeping, and 22 to what extent do you protect us from the inspectors and the 23 fact they are not required to conform?
]
24 MR. PETERSON:
Don, I think we left it, didn't 25 we--we had a big discussion in the working group as to how we HERITAGE REPORTING CORPORATION -- (202)628-4888 i
1 43 1
should structure that.
Should it be everybody?
We left it if f
2 you are required to monitor, then you report.
And the others, 3
you know--Walt?
4 MR. WALTER COOL:
Walt Cool--just an add-on there--
5 if you are required to monitor, then you have to record and' 6
you would have to file the report.
7 If you monitor for your own good reasons, and I 8
recognize that is a factor in many cases, then you wouldn't 9
have to report.
However, in considering the reporting 10 requirement, I know a lot of cases that just send in a copy of 11 the end of year report dosage would suffice, and that may or 12 may not differentiate between those who have to be reported
/~T 13 and those who don't.
V 14 HR. SHAPIRO:
I was referring particularly to the 15 requirement to provide individual workers with records; four 16 thousand, five thousand people we have registered.
Very few 17 really require registration.
Would every one of those have to 18 have a record?
19 MR. WALTER COOL:
Here again, it is tied into the 20 requirement that they have to be monitored.
If they don't 21 have to be monitored, you wouldn't have to tell them.
The 22 psychology might be a question, though.
23 HR. PETERSON:
Okay.
There are numbers indicated, 24 number of changes that we have done to the proposed rule that 25 actually increased the implementation costs.
HERITAGE REPORTING CORPORATION -- (202)628-4888 l
L 44 1
One of the first ones is deleted the exemption that
()
2-was in the proposed rule for long-lived radionuclides.
This 3
would have allowed control on annual doses.
Now this is 4
partially inconsistent with the NCRP, as Dr. Moeller indicated 5
earlier, because everybody is in-agreement this is us, the NRC 6
rule, the NCRP, and the federal guidance that for the sake of 7
planning and control purposes, you use the committed dose 8
equivalent for internal exposure.
9 This is nothing new.
The only thing new is the fact 10 that they came up with a term called committed dose 11 equivalent.
ICRP 2 concentrations are based upon a committed 12 dose equivalent principle because if you get that
()
13 concentration over 50 years, at the end of the 50th year, the 14 dose rate to the critical organ will be the dose limit, and 15 that's how all of the previous concentration standards were 16 set.
17 What we have done in asing that concept is we have 18 also applied it so that the doses committed that year--this is 19 a record keeping thing where you take the dose from that 20 year's intake and assign it to that year.
Again, if that 21 worked out with uniform exposure over the lifetime, at the end 22 of the 50th year, the worker would be getting the limiting 23 dose rate.
If he had a limiting intake, all along getting the 24 limits dose rate to the organ, the purpose of doing that is 25 for the sake of bookkeeping, that if in order to do it in i
HERITAGE REPORTING CORPORATION -- (202)628-4888
45 1
terms of annual dose rate requires the monitoring of the
()
2 individual on a yearly basis or more frequently, in some 3
cases, this is can be done.
4 The control on the basis of an annual dose limit to 5
an organ from internal is really a control on the worker.
It 6
is not a control on the work place, and I think there is a 7
difference in the philosophy that we have with NCRP and why we 8
are being more restrictive.
We don't feel that we can 9
restrict the worker on the basis of a current body burden.
10 Essentially what would happen, if somebody got a large 11 overexposure internally, they would get the committed dose 12 equivalent assigned to that year, get a citation probably and 13 enforcement action to go with it, and then that does is
(}
14 forgotten.
We would not reduce subsequent annual doses on the 15 basis of that body burden.
16 Now that is I think maybe a point of contention, but 17 the staff feels that we cannot control the worker.
In some 18 ways, for example, if suppose the annual dose rate was 19 sufficiently high that it exceeded the 5 rem effective dose 20 limit?
That person couldn't work in the nuclear field.
We 21 can't, we have no authority like say our sister agency DOE to 22 say okay, now you put that guy in some non-radioactive 23 employment.
NRC can't do that.
So it is really designed to 24 really protect the worker, the employability of the worker in 25 terms of application.
HERITAGE REPORTING CORPORATION -- (202)628-4888
46 1
Now the problem with repealing 2205, the option--or I
2 not continuing it, has to do primarily again with what I 3
mentioned before, the fuel fabrication facilities who are also 4
helped with this five-fold drop in the allowable air 5
concentration, and it is the combination of the two.
Not 6
doing 205, 205 I think would have gotten them I think out of a 7
lot of the problems with the committed dose equivalent.
8 The cost of this option is probably in the 9
neighborhood of S75 million total for the fuel fab facilities 10 to put, put in control measures.
They may have to go--Paul 11 Stansbury is going to talk later--may have to go to a glove-i 12 box line in some cases.
Depends on the process.
(}
13 I mentioned also annual reporting of individual 14 doses by the 24, what is now the requirement of 20.408 in the 15 present rule to get individual dose statistics.
l 16 This will do several things.
One, it will act as a 17 prototype for some sort of national registry of radiation 18 workers that the National Cancer Institute is interested in.
19 Secondly, it will eliminate some of the problems 20 between NRC statistics and industry statistics, particularly 21 from the nuclear power plants.
There is one I think comment i
22 in the statement that was done on the basis of the fact if NRC 23 uses the groups, we tend to get a higher collective dose t
24 because it is generally log normally distributed, and so the l
25 larger number at lower dose levels, even within the group i
i P
HERITAGE REPORTING CORPORATION -- (202)628-4888
~ ~
47 1
range, so as a result, our collective doses come out about 25
()
2 percent higher than the industry's collective dose, which is 3
done by assuming certain numbers.
If we both have the same 4
set of numbers, we should be able to produce the same total so 5
that this is a minor but an interesting benefit coming from 6
that.
7 CHAIRMAN MOELLER:
Let's take 15 minutes.
8 (A brief recess was taken.)
9 CHAIRMAN MOELLER:
The meeting will resume, and we 10 will continue with Hal Peters on's presentation.
11 MR. PETERSON:
We have made some other changes from 12 the proposed rule that are not as significant as those I
(}
13 mentioned previously.
We have reinstated some detailed 14 protection requirements for larger irradiators.
These 15 requirements are nothing new.
They are reworked, but they 16 are, essentially follow 20.203G in the present Part 20.
17 We have separated out essentially three sets of 18 requirements.
There is a requirement for a high radiation 19 area that applies to all licensees.
There is a requirement 20 for protection in very high radiation areas that applies for 21 all, to all licensees, and then there is these very detailed 22 specific procedural requirements that apply to high energy or 23 high-level or gamma irradiative facilities.
24 We have also changed record retention periods from 25 the two to five years.
This is just a consistency with the HERITAGE REPORTING CORPORATION -- (202)628-4888
l 48 i
1 NRC policy on record retention.
This deals with most of the
()
2 general radiation protection records.
It does not deal with, 3
of course, dose records or survey data that are the basis of a 4
dose _ assessment such as a, for air concentration survey data,
-5 and those must be kept for the life of the license, which is 6
consistent with current policy.
7 One area that has generated considerable controversy 8
is the calculation of collective doses and a cutoff that was 9
proposed in 20 Section 20.304 of the proposed rule that would 10 essentially have eliminated collective doses when the 11 individual doses were less than a millirem or more, or 12 less--I'm sorry--were less than a millirem per year to the 13 individual.
14 The purpose of cutting this section out was 15 two-fold, primarily because we have adopted the industry's 16 comments which was, this was good but what we really need is a 17 below regulatory concern level-that will do, allow us to do 18 things like not have to account for every last atom and use 19 some unrestricted disposal of very slightly contaminated 20 material such as soil, which is a big problem in some cases 21 due to very trace levels of radioactivity.
22 We have adopted essentially that suggestion 23 primarily because it was made also by a Congressional 24 Committee in one of our authorization bills, and we are in the 25 process of setting up a policy on what we call or what EPA HERITAGE REPORTING CORPORATION -- (202)628-4888
49 1
would call below regulatory concern, that is, levels that.are C)
(_
2 so small they are not of any significance health-wise and that 3
they can be unregulated by NRC.
4 We took the section that was in there out of the 5
rule because we felt it might conflict with whatever policy 6
within the comprehensive policy we came up with, and also we 7
also noted that Part 20 doesn't require the calculation of any 8
collective doses, so we felt that there is no reason to 9
specify how they should be calculated.
10 And lastly, there is no cost impact that we know 11 from this deletion.
The only place in the NRC regulations 12 where a collective dose is really required to be calculated is 13 in a Appendix I, 10 CFR Part 50, and in the entire history of
()
14 that rule, with or without a collective dose cutoff, that 15 collective dose has never required one single piece of 16 equipment to be installed in a rad waste system in our, any 17 reactor in this country, so there is no financial impact of 18 this.
19 CHAIRMAN MOELLER:
Let's pause there a moment.
Do 20 Mel or Jack, Charlie, do you have any comments on this?
Shoot 21 from the hip.
If they are going to handle the matter under 22 the BRC label, then you know, it is okay with me.
23 While I have interrupted, I would like to go back to 24 the committed dose for the emitters.
Do you want to talk 25 about it now or it was on the previous page, or wait until the HERITAGE REPORTING CORPORATION -- (202)628-4888
\\
~50 1
end?
I would like to know your thoughts and comments.
(
2 MR. CARTER:
I would just as soon take it up at the 3
end.
4 CHAIRMAN MOELLER:
Then go ahead, Hal.
5 MR. PETERSON: -Okay.
One point--this gets back into 6
the sewer systems, I think Dr. Moeller, of course, is correct 7
with sewage being the combined of the sewer, the pipe, plus 8
the sewage that is in it, so we did intend in the rule to use 9
sewage as the combined total, and what we have done here is 10 simply codified a position that we have always. applied but 11 never had in the rule which was that if.a licensee in, and we 12 are thinking primarily the power reactor facility in this
(}
13 case, have a three line sewer treatment plant, putting the 14 waste into three sewer line doesn't constitute disposal into a 15 sanitary sewage system, that they must meet the disposal 16 limits at the sewer outfall for liquids and not the higher 17 number for sewer which assume some sort of internal dilution i
18 occurs due to the presence of non-radioactive material users.
19 CHAIRMAN MOELLER:
Well, in your sewer disposal 20 consideration, did you look at the sludge and the possible 21 uses of the sludge?
22 MR. PETERSON:
We have at this point not in setting 23 these limits per se.
It was a consideration in the fact that 24 we did bring the limits down.
We have a study right now
[
t 25 ongoing at PNL that is looking at sewer systems, and the fact i.
l l
HERITAGE REPORTING CORPORATION -- (202)628-4888 l
A 51 1
all the dose-pathways both at the sewer treatment plant
()
2 occupationally, and also for uses of the sludge as you N
3 mentioned which can be used and has been widely.used for 4
supplements for-agricultural purposes.
There is a distinct 5
problem with, with that anyway in most cases.
There are 6
other, there are heavy metal, so that this is not the sole 7
purpose, but we are looking at that, and that might be one 8
area that on the basis of that study might be somewhat 9
modified in terms of a further amendment to Part 20.
-10 Lastly, with these other changes, we have reinstated 11 the incident notification criteria that were based on monetary 12 loss and loss of use of the, a facility.
Just this is
- (}
13 consistent with the present rule.
And there were a few recent 14 events that happened that made people somewhat anxious about 15 their absence in the proposed rule that we put them, put them i
16 back in.
t 17 Now to sum up, with the agreements, Allen Richardson 18 from EPA made a point to me that I have sheets in here of 19 agreements with ICRP.
This agreements with ICRP, whether in 20 agreement with NCRP of disagreement with NCRP, and I don't 21 have any sheet here with agreement with the federal guidance, a
22 and it is well taken and the reason is we assume that we have 23 complied exactly with almost all, with all of the premises of 24 the federal guidance, and so that there is no need to say this O
i 25 is what, what we did and what we didn't do.
They should be HERITAGE REPORTING CORPORATION -- (202)628-4888
52 1
parallel and consistent.
()
2 With ICRP we have, as I mentioned before,' adopted 3
the annual dose limits for workers and for the general.public.
4 We have used the effective dose equivalent concept.
We-have 5
employed 50 year committed dose equivalents for internal 6
doses.
We have required summation of internal and external 7
doses if both are required to be measured.
I might add that 8
was some point in the proposed rule.
There was a lot of t
9 misreading as to what we required.
Many people thought we 10 required measurements as low as 10 percent of the dose limit, t
11 and this was, it is really a projection of what the person 12 would be likely to be exposed to because obviously if you are r
I 13 going to determine whether you are going to monitor them, you
()
14 have got to make that decision before he goes in the 15 radioactive area, so there is some difficulty.
We hope we f
j 16 have clarified in the statement about what is meant by the 17 threshold on monitoring.
18 We also adopted the ICRP 30 methodology and 19 parameters for internal dose calculations which were updated, 20 I said our 30 year old values that have been changed I think 21 once before in the future primarily on the basis of the FRC i
22 guidance.
We are now putting primarily ALIs on annual dose r
23 limits, and associated derived quantities such as the annual
[
24 limit on intake and derived air concentration.
l I
25 Also compatible with the ICRP is the use of planned l
HERITAGE REPORTING CORPORATION -- (202)628-4888
53 1
special exposures which provide additions to above the
()
2 exposure, the exposure limits, and I might add there was one 3
thing earlier that I said that in the case of an overexposure 4
we would quote, forgive it.
We would forgive it except, of 5
_ course, it goes into the record and it is also subtracted from 6
a lifetime budget if you wi.11 for planned special exposure.
7 And that lifetime budget if the same as the ICRP and that is 8
25 rem and so that any overexposure gets reduced, that bank 9
gets reduced by that amount, or so that is taken into account.
10 We did depart from ICRP in certain areas.
One was 11 the protection of the cmbryo fetus.
We followed both the 12 NCRP, which is also the federal guidance number, which is a
()
13 half rem off the gestation period rather than one and a half 14 rem as the ICRP value.
i'3mbers of the public, I already 15 alluded to that about the long-term average versus the annual 16 dose limit, and I also mentioned the half rem limit that is 17 available upon approval of the Commission.
18 We did restrict and the proposed rule did restrict 19 the intake or the use of the planned special exposure in terms 20 of an annual dose.
We allow only up to the dose limit in 21 addition so that we allow 5 rem addition to the normal limit.
22 ICRP would allow you to have used 10 rem in addition to the 5 23 rem.
That's a mean or change.
As I said, the 25 rem lifetime 24 limit is the sama.
25 We do not totally go along also with the type A and HERITAGB REPORTING CORPORATION -- (202)628-4888
54 1
B working conditions of the ICRP and have standa rdized the sm
( )
2 monitoring requirement at 10 percent of the dose limit rather v
3 than 30.
There are a large number of industry commsnts that 4
said the 30 percent was too large, too large.
It would be one 5
and a half rem to overlook, so that that was one of the 6
reasons we did that.
7 The NCRP had made some of the recommendations of the 8
new UCRP 91 report.
We have included, Dr. Moeller indicated 9
we have not included some, and these are ones we have not 10 included--the cumulative lifetime dose limit of one rem times 11 the age of the person in years; primarily we had no 12 opportunity to collect any comments, public comments on the.
<3 13 use of this, so we felt we could not do it.
We were operating q) 14 under a very cardinal principle and that is thou shalt do 15 nothing to caure the rule to have to be reproposed because 16 that is another two-year delay.
17 Secondly, I mentioned the use of the committed dose 16 equivalent in great depth, I think for planning purposes and 19 not for control or for control and not for post-exposure the 20 way we use it.
i The embryo fetus limit in NCRP 91, they also have a 22 monthly dose rate limit of
.05.
The NRC says the uniform, the 23 exposure must be uniform throughout the gestation period, and 24 of course, if you divide
.5 by 9, you come up with 0.055, R/
25 which is close enough to the NCRP.05 monthly limit that we HERITAGE REPORTING CORPORATION -- (202)628-4888
55 1
think we have, are in. compliance with that, that suggestion i
(
2 also.
3 I shouldn't say compliance.
We are in agreement.
4 We don't comply with the NCRP.
5 Lastly, there is some questions about site operators
[
6 in the NCRP report to assess total exposure to the most 4
i 1
7 exposed individual member if they exceed 25 percent of the l
8 limit.
9 We feel it is a great difficulty to impose upon a 10 licensee to assess doses from sources beyond his control to 11 members of the public.
Consequently, the way wo apply our 12 numbers is in terms of the dose from the licensed facility to 13 an individual in the public, and the exception, as we i
14 mentioned before, with regard to 40 CFR 190 and.the EPA 15 standards is the way 40 CFR 190 is calculated, it is the dose c
16 from the fuel cycle to any person, and consequently, it is 17 viewed as a sum and in some cases where there are adjacent 18 nuclear facilities, that is evaluated separately.
19 Okay.
The NCRP also mentioned the use of reference p
20 levels.
So did the proposed rule.
This is something we feel 21 that is very much the--we know the licensees do it.
They will 22 adopt a lover internal working lisit for their plant that is 23 lower than our standard because it gives them the assurance
[
24 that they don't exceed our standard We are not going to tell
(
25 them how to do that.
We are worried about the end result.
j HERITAGE REPORTING CORPORATION -- (202)628-4888 I
t L
56-1 Lastly, the NCRP proposed a concept of negligible
()
2 1svel of one millirem a year to be allowed under the practice 3
of ALARA.
That will be considered as part of the this BRC 4
policy.
5 I should say one closing thing.
There has also been a
6 recommendations by the UK, NRPB--Nationel Radiological 7
Protection Board--where they have recommended or they have 8
been attributed to have recommended a reduction in the dose 9
limits down to, for workers down to 1.5 rem per year.
What 10 they actually recommended, and this is a very close paraphrase 11 of their recommendation, is that the average exposures be kept 12 below 1.5 rem per year.
13 And again, they adopt the public limit of a hundred 14 millirem with a critical group dose from just discharges for 15 nuclear installations of 15 millirem.
We, of course, have 40 16 CFR 190, which makes it 25 millirem, so we are even below them 17 ti.ere.
I might point out just one slide.
18 CHAIRMAN MOELLER:
While you are doing that, had 19 missed the fact, and I think it is good that you pointed it 20 out, that they are saying an average effective dose equivalent 21 of one and a half rem a year, so it is not what many people 22 are saying.
23 MR. PETERSON:
Right.
It is really not a reduction.
24 This is a plot; I made a few--it is a little old.
I made it a 25 few years ago.
HERITAGE REPORTING CORPORATION -- (202)628-4888 L
o 57 1-(Slide)
-( )
2 MR. PETERSON:
But it is a plot.
Basically the 3
important thing, the solid dots are the occupational exposure 4
doses in nuclear power reactors.
This is a several years 5
worth of data that has been combined here.
This is the annual 6
radiation dose in rem, and this is the percent of the 7
population that gets less than that number, so it is a 8
cumulative frequency distribution on the log normal plot.
And 9
see the low levels.
It is, one can say that there is a log 10 normal.
11 The important thing with regard to the British 12 position if you go up here, this point is about one and a half
_( }
13 rem, and you can see that this translates to roughly 90 14 percent of the exposures being below that, so we don't feel 15 that there is a need for any additional control since we 16 already are fairly well below the British guidelines.
17 Questions?
18 HR. SHAPIRO:
Is there very much discussion on the 19 organ cap of 50 rads for a single organ in view of your own 20 paper you talk about lowering doses and so forth?
21 HR. PETERSON:
There wasn't too much.
There was 22 quite a bit of comment really, and I just remembered I didn't 23 answer the question that you had asked earlier about the doses 24 to the public.
There has been quite a bit written about the 25 fact, and it has to do with what I consider a fairly dumb HERITAGE REPORTING CORPORATION -- (202)628-4888 i
58 1
thing that they included in ICRP 26.
l) 2' There is a offhanded remarks after they give the 3
basis limits that if you need a dose limit for an organ, what 4
you do is take the effective dose. limit, the 5 rem per year, 5
and divide it by the weighting factor, the W sub T.
If you go
~
6 through that process for those things that you really would 7
like organ dose limits or might have an application from, you 8
find I think for some of them like bone it comes out to 42 9
rem, which isn't much different than 50.
For thyroid with the 10 WT of
.0, you get 160 rem, and a lot of people have been 11 complaining that the new ICRP approach would allow 160 rem to 12 be given to the thyroid and the several other organs that
()
13 would get high numbers, and of course, what happens is then at 14 that point,-you really hit this 50 rem, not stochastic dose 15 limit.
That is a capping dose, so that's where the comment 16 has really come up in a misunderstanding.
We had a lot of 17 comment, 160 some odd comments from the general public that 18 don't raise the limit, and I think that gets back at a 19 question you had asked about the limits for the public.
20 (Slide) 21 HR. PETERSON:
There are two tables here.
This is a 22 very busy slide.
We will give copics of this to the task 23 group, but this is the form of Part 20 concentration, the revised Part 20 concentration, and the direction and in fact O.
24 25 they go down for most some of the important radionuclides that HERITAGE REPORTING CORPORATION -- (202)628-4888 L
59 1
I could think of.
Tritium as you can see goes down, cobalt (f
2 down, krypton, up, et cetera, you can see.
Some go up.
Some 3
go down, and really the biggest changes you get are out here 4
There is as factor there, well 5
here, thorium 232 is 250 in this case for this thing.
It is 6
60 in the water.
And uranium--now this is soluble uranium--it 7
is no change.
Insoluble uranium, there is a factor of 5, and 8
that's what the problem is, but there is no consistent 9
direction that you could say that the concentration limits for 10 the public, the fact you have gone from half a rem to 50 11 millirem combined with the changes in the, in the metabolic 12 models and so forth, it is difficult to say that there is an 13 overall change in the occupational.
As I said, there is a 14 change that most of them go up.
15 HR. SHAPIRO:
What I had in mind, we did have a 15 16 rem organ dose limit, and using your weighting factor 17 concepts, you do go up to the lung, you go up to close to 50 18 allowable, that I was wondering to what extent you may or may 19 not have had comment on that change.
20 MR. PETERSON:
That was about the only extent that I i
21 remained--Don, Walt, do you remember?
I don't remember seeing 22 anything else.
Also I should add that since the numbers were 23 going up, industry is, generally doesn't comment on things 24 that are favorable.
It is usually the ones that hurt them
(
25 that they comment on, so--but we didn't see a comment on that HERITAGE REPORTING CORPORATION -- (202)628-4888
60 1
area.
It was more from the public complaining about the level
)
2 and really the increase in the DACs occurs more in the, to the 3
members of the working population than it does to the public.
4 CHAIRMAN MOELLER:
To be sure I understand, you have 5
then applied just a 50 rem uniformly as a stochastic limit for 6
individual organs?
7 HR. PETERSON:
To both air and water pathways, so 8
you can think of it if an individual were to receive exposure 9
from both.
10 CHAIRMAN MOELLER:
Now when ICRP did its calculation 11 say for the lung, did they use 40 rem?
12 MR. PETERSON:
Would have used a, the stochastic 13 limit, which would have been 40.
[}
14 CHAIRMAN MOELLER:
So there is not all that much 15 difference?
16 MR. PETERSON:
In fact, there is no difference in 17 that case because we would have, we would have used their 18 number.
19 CHAIRMAN MOELLER:
Well, then I am confused.
If the 20 ICRP number for dose, say on something you have inhaled that 21 insoluble and the lung is the critical organ, if the ICRP 22 number is based on 40 rem a year and yours is based on 50, I 23 mean you have told me that you are using 50 rem a year.
24 HR. PETERSON:
For the case, thc non-stochastic, the 25 case where the stochastic limit is governing, we use the HERITAGE REPORTING CORPORATION -- (202)628-4888 i
61 1
stochastic limit for the work, in which case it is the 42.
O
(_/
2 There are some cases like the thyroid where the non-stochastic 3
limit or the stochastic limit would be 160, would be the 5, 4
and those we have used the 50 rem capping dose, and that's 5
consistent with ICRP.
6 For the worker--for the non-worker, the public, 7
there is no capping dose in terms-of a non-stochastic effect 8
because it is sitting up at 50 and there is no way they can 9
get at it, so all of it is based on the non-stochastic, or the 10 stochastic.
11 CHAIRMAN MOELLER:
Well, let's look at 10 CFR 20 on 12 page 7 of what we were given, and I either misread or i
(}
13_
something.
You people have the definition of ALI on page 7, 14 okay.
Now there it says, take the second sentence, ALI is the 15 smaller value of incake of a given nuclide in a year by the 16 reference man which would result in a committed effective dose 17 equivalent of 5 rem or a committed does equivalent of 50 rem 18 to any individual organ or tissue.
Well, if I'm reading, you 19 are telling me the lung limit is 50 rem a year.
20 MR. PETERSON:
No.
It is the smaller of the two.
21 And in this case, if the lung limit is 42 rem, based on the 22 stochastic limit, the smaller of the two, 42 being smaller r
23 than 50, that is the limit.
i 24 CHAIRMAN MOELLER:
Oh, okay.
That's where you were 25 saying take the 5 rem and divide by the weighting factor.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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62 1
MR. PETERSON:
That's the ICRP suggestion.
It just
()
2 happens for.aost of the nuclides that you really would like an 3
equivalent organ dose limit.
It doesn't work because you hit
[
4 that 50 rem.
5 CHAIRMAN MOELLER:
I didn't see.
I understand now, 6
so yes, you are following exactly the same thing, t
7 Okay.
Other questions or comments?
I think~one 8
approach we could use is to ask for public comment, and we 9
have on our agenda several people who-had asked or at least 10 one person, Paul Stansbury--would you want to speak now?
You 11 are through, Hal?
l:
12 MR. PETERSON:
Yes.
()
13 CHAIRMAN MOELLER:
Could ycu come on up and give us 14 your comments?
And then if there are others who want to 15 speak, we will hear them and then we will get into our i
16 discussion.
17 MR. STANSBURY:
I am Paul Stansbury, and I'm from 18 GE's Nuclear Fuel and Components Manufacturing Plant in 19 Wilmington, North Carolina.
i l
20 I wouAd like to start a little bit, however, on a u
I 21 bit of a personal thought.
I am tickled to see some of the 22 progress the staff has been able to make technically in the 4
l 23 areas of electronic media, and the ALARA which were comments i
24 from industry with which I am familiar.
j
~
25 I would, also wish I had the opportunity and envy I
I HERITAGE REPORTING CORPORATION -- (202)628-4888 l
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63 s
1 the work of the committee to be able to comment on the entire
()
2 draft.
To me, this is very interesting parts that have to be 3
addressed.
40 CFR 190 compliance which will be required by 4
references is kind of interesting because 40 CFR 190 doesn't 5
define what a rem is, and it will be curious to see whether it 6
is rem to organ or effective rem, that applies to the organ 7
dose limits and those sorts of thing, but I am sure the i
8 Committee will take those up this afternoon.
9 Likewise, what is the role of skin particle, hot P
10 particles in skin dose, particularly in light of NCRP 91
.11 recommends, averages the dose for stochastic concerns over the l
t 12 entire skin of the body and using weighting factor of 3
(])
13 percent.
It is an interesting thing your Committee would get i
14 into.
- However, GE--
15 CHAIRMAN MOELLER:
Excuse me a second.
Now on 40 1
16 CFR 190, to refresh my memory, it says 25 millirem a year for 17 the whole body but 75 for the thyroid?
{
l 18 HR. STANSDURY:
Twenty-five for any other single 19 orgaa.
I l
20 CHAIRMAN MOELLER:
That is totally inconsistent.
i 21 MR. STANSBURY:
It was an ICRP 2 concept, not ICRP l
22 26 and 30, but those are not really the comments I come to 23 make.
d
)
24 CHAIRMAN MOELLER:
Sure.
l I
25 MR. STANSBURY:
I do have some vugraphs, and Mr.
t HERITAGE REPORTING CORPORATION -- (202)628-4888
l 64 1
Igne, did you prepare copies for members of the Committee?
(f 2
Would you want to pass them out?
3 HR. IGNE:
I just did.
4 (Slide) 5 HR. STANSBURY:
Thank you.
This is an outline of t
6 the topics that I would like to cover.
y would like to speak 7
in favor of retaining the proposed paragraph 20.205 provisions 8
for internal exposure involving radionuclides with very long 9
effective half lives, and I really do like this title because 10 it is somewhat neutral.
If you call them exceptions for 11 persistent radionuclides, that sounds bad.
The case 1 would 12 make today is that they are, it is actually a preferred 13 alternative for dealing with radionuclides with very long 14 effective half lives.
To say the idea of provisions is 15 somewhat neutral and perhaps appropriate.
16 I would maintain that the provisions that were 17 proposed are in line with national, international, 18 presidential guidance and professional society 19 recctmendations.
Deletion of that paragraph is not in line 20 with national, international, presidential guidance and 21 professional society recommendations.
22 Deleting the paragraph makes the NRO approach I
23 inconsistent with the approach taken by DOE.
The provisions f
24 as written in the previous draft would promote the use of lung i
25 counting in the commercially uraniun fuel fabrication HERITAGE REPORTING CORPORATION -- (202)628-4838
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1 industry.- As I will point-out, that has some operational
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2 advantages for the worker, the licensees, regulators,-and 3
perhaps even defense lawyers further down the road.
4 Part of the problan, and if time permits I would get 5
into that, the use of lung counting to ascesa personal doses i
6~
avoid rather extensive conservatism that is built into 7
calculation of the committed effective does equivalent to l
8
_ reference man for the purposes for which it was done.
Perhaps 9
that conservatism is appropriate.
On the other hand, I am not j
10 sure the conservatism is something that the country can 11 afford.
t 12 Deletion of the proposed prragraph, or to be
}
13 determined by air sampling which is, essentially is the
(}
14 current methodology today--the noi.rness of pleasant plant P
15 conditions, I am speaking for GE but I know from indirect 16 associations and talking with other people what I spea': of is 17 fairly representative of other licensees, will require large 18 costs to the industry, and I will get into that.
So if I may, 19 I would like to go through these point by point, Mr. Chairman, i
i 20 I presume you and your Committee would interrupt me if you 21 have questions.
22 CHAIRMAN MOELLER:
Fine.
t 23 MR. STANSBURY:
I precared about a 15-minute L
24 discussion, but I will take as long to answer questions as you 25 desire.
i i
HERITAGE REPORTING CORPORATION -- (202)628-4888 i
66 1
(Slide)
= V)-
./
2 HR. STANSBURY:
There is another national, 3
international guidance.
I would presume on the Committee with 4
your-familiarity with'the guidance.
I won't be long winded 5
about this, but if we look at ICRP 26 or paragraphs 175, 76, 6
and ICRP 30, these documents propose the committed effective 7
dose equivalent, and you will notice in reading them that even 8
here, they rely--there are some shortcomings to the committed 9
effective dose equivalent.
ICRP 30 talks about the dose 10 equivalent which work he has actually received plus that which 11 he might be committed as a result of exposure is important in 12 determining his radiation status; 84 is extremely explicit.
I
-j 13 apologize for not quoting then correctly in that the "not" V
14 here should be underlined in this text or 4talicized in the 15 ICRP text.
Committed equivalent dose equivalent should l
l '
16 specifically not be used as a measure of individual workers' 17 exposures status, and they further go on to talk about a 18_
system that essentially is an annual dose system.
19 (Slide) 20-MR. STANSBURY:
The federal radiation grotection 21 guidance for o" upational exposure developed ess'entially 22 concurrently with the Part 27 changes is also rather explicit 23 the limiting value for assessed dose to individual workers 24 should be based on the annual effective dose equivalent,
.f') ~
(/
25 summarizes what the presidential guidance says.
Limits values 1
HERITAGE REPORTING CORPORATION -- (202)628-4888
i 67 1
- for cortrol of the workplace should be based on committed
.s(,)
2
~ dose.
7t is not completely clear in the presidential guidance 3
and in fact EPA themselves in interpreting the guidance in 4
commenting on Part 20 would reverse this, but to me it is 5
fairly clear and fairly obvious from the fact that these are 6
italicized in the text exactly what is meant in the 7
presidential guidance.
8 CHAIRMAN MOELLER:
Execute me.
On NCRP on your 9
previous slide, why did you quote 84 rather than 91?
10 MR. STANSBURY:
I quoted 84, one because 91 11 references back to 84 as what to do with internal exposure, 12 apecifically, Dr.
- h elle r, page 4.
(")T 13 CHAIRMAN MOELLER:
And "'ey
?,
they are compatible 14 I would hope, the two statements?
15 HR. STANSBURY:
As reasonably compatiole as a dozen 16 health physicists can ever get.
17 (Slide) 18 MR. STANSBURY:
Removing paragraph 20.205 puts NRC 19 licensees under a system that is different from the system l
20 being considered by the Department of Energy as they implement 21 the presidential guidance.
They are specifically going to an 22 annual effective dose equivalent to control workers' 23 exposures.
This is a draft from their '37 version of there 24 Chapter 11.
This will have NRC licensees having the joy of L
25 having to justify sometime in the future in court whe.. the NRC l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
68 1
ts not helping them why they ara doing something differently (3
(,)
2 than the U.S.
Department of Energy.
3 The DOE feels rather strongly about that, and in 4
fect their comments on Part 20, they said the NRC should not 5
have a dual system using committed dose and annual dose.
It 6
should all be based on annual dose, and of course, for short 7
effective half-lived nuclides, it doesn't really matter 8
whether you are looking at the dose during the year or whether 9
you are looking at the dose over an extended period of time.
10 (Slide)
-11 MR. STANSBURY:
And the Health Phys $es Society got 12
- .nto the debate on this issue.
Back in the '82 and '83 time 13 period there ' Y 3 a study group, uranium fuel fabricators, who 14 met and worked with the staff on the evolution of the draft of 15 Part 20 and we were delighted to have the opportunity to do 16 that. 17 At that time, we had developed the paragraph 20.205 18 limiting their again annual dose from the persistent 19 radionuclides to 3 rem annually. Subsequently they got more 20 concerned. There was an ad hoc committee to the Board of 21 Directors in 1984, not 9184. The Health Physics Society Board 22 of Directors adopted the Committee recommendation that design 23 and planning should be based on committed dose.
- However, 24 intakes of persistent radionuclides committed does should be 25 managed on the basis of annual dose.
The Health Physics HERITAGE REPORTING CORPORATION -- (202)628-4888
1 69 1 Society reaffirmed the Board position. This is a 6,000 member -( )' 2 professional organization. 3 (Slide) 4 MR. STANSBURY: Shifting gears a little bit, I would 5 'like to talk a little bit about committed dose-and annual 6 dose. And first, to realize there are some points in common 7 under either approach in the uranium fuel indust':y urinalysis 8 studies are needed to control intake ot soluble uranium to the 9 soluble intake uranium limit. Regardless of which system is 10 used for workers consistently exposed to--under either 11 systems, the lifetime dose would be approximately the same, 12 which to me it is a hypothetical case. We don't have 13 workers--I say approximately that's within a factor of 2--we 14 don't have workers that are at this limit in commercially 15 uranium f al industry that I know of, and the folks that work 16 at our plant; I am not aware of it in any other commercial 17 fuel fabrication plants. 18 The other thought is ALARA efforts underneath the 19 limits really are going to control the dose the average 20 workers get. They have so far, and I have reason to believe t 21 that the staff would continue their vigor in getting licensees t 22 to do ALARA and these efforts would really control the average 23 dose to the workers, not what the upper limit is. 24 (Slide) 25 MR. STANSBURY: Under a committed dose control, you l l HERITAGE REPORTING CORPORATION -- (202)628-4888
70 1-have to determine a'large number of small intakes. We can do 1 [). 2 that by air sampling which'is what we do at our plant. In 3 theory it could be done by fecal sampling on a daily basis. 4 For our 500 workers, that could be tough. 5 Representativeness of air sampling is always an 6 important issue when air sampling is your method of 7 determining dose. We have lived with that for a while. When 8 your doses are far underneath the limit that may confuse that 9 issue. The thought is all air samplers measure air the worker 10 didn't brea'the, and yet that is the method that is used to-11 determine compliance with NPC hours. Today under the new Part 12 20 without paragraph 20.205, it is the method to determine the 13 dose of record. There is a weakness there. { 14 The practical applications require the ur of 15 reference man values for lung clearance. It is conceivable 16 that the current draft could have some things that talk about 17 individual cases, but after a quarter or a week or whatever 18 your control measure is, that you have exceeded or if you have 19 exceeded perhaps a regulatory limit, an ALI, it does you very 20 little good in a practical sense two years later to discover 21 that you really didn't exceed an ALI because it is clearing l l 22 for our 5 rims more rapidly than reference man would suppose. 23 Representativeness kills the use of particle size l l 24 adjustment of DAC. There is provisions in ICRP 26 and 30, 25 perhaps in the Part 20, to be able to adjust the derived air l HERITAGE REPORTING CORPORATION -- (202)628-4888
71 1 concentration'for particle size. We have done some crude 2 measurements around our plant that would indicate that perhaps 3 a DAC based on 1 micron is a factor of 2 to 3 lotter than it 4 needs to be. The killer issue is to tell the inspector when 5 he says how do you know what the particle size was when this 6 particular incident came up that delivered the large dose? 7 Now there are again the theoretical fellow says just have the 8 guy wear eight stage lapel sampler and you would know that for 9 sure. 10 Overexposures, there again, ALI 2,000 DAC hours 11 would restrict the worker to remainder of the calendar year, 12 generally have no effect on the management of that individual, (~)') 13 i.e., they would be written off. 14 Lastly, with removal of the paragraph 20.205, it 15 becomes difficult for a health physicist to justify to his 16 management why they should have an expensive lung counter when 17 it doesn't really help them in their compliance program. May 18 have legal concerns in the future, but it does diminish the 19 practical importance of a lung counter. 20 (Slide) 21 MR. STANSBURY: Annual dose control, a new system if 22 you would, for NRC licensee, compliance could be demonstrated 23 by determining time weighted lung contents. It is my real 24 rough estimate that this could be done with monthly and 25 quarterly lung counts, and for my facility in which I am a HERITAGE REPORTING CORPORATION -- (202)628-4888
.72 1 health physicist, about 4 times as many counts per year would m ( ). 2 provide a system that would probably work. 3 The one count limit for low enrichment uranium 4 doesn't change much for ICRP 2 even using ICRP 26 and 30 5 values. I will walk you through that calculation briefly 6 here, but essentially, it comes out about the same. One 7 event, when your lung counting is down near the lower limit of 8 detection, lung counting is fairly inaccurate. As one 9 approaches what would be considered the organ limit, lung 10 counting does becone more accurate. Lung counting is a direct 11 measurement. No question of representativeness; no question 12 with somebody being able to say oh, yes, I remember my lapel ~ 13 sampler was off that 20 years ago when the incident occurred 14 that is the basis for this lawsuit. 15 Lung counting automatically accounts for individual f 16 clearance times, particle size, and solubility. We mentioned 17 from the positive standpoint that the Health Physics Society 18 and ANSI have been working together. There are almost 19 available performance criteria for lung counting that should 20 be available very, very shortly to make that a system which 21 would work. 22 Lung counting acccunts for previous intakes. It 23 does not write off the other doses. The write-off is the 24 problem. Even if you are allowed to under a DAC hour sort of 25 approach, you make lung count, you have got to decide how much HERITAGE REPORTING CORPORATION -- (202)628-4888
73 1 uranium is from last year and now how much uranium is from r) (,j 2 this year?- If one is using a committed dose concept, it makes. 3 the interpretation of lung counts tough. If you'are using 4. annual dose system, it is very simple. The average of a 5 normal of lung counts is either above or below a limit. 6 Air sampling would still be necessary and'useful to 7 control the factoring environment on a day-to-day basis. 8 Action guides would have to be referenced to the DAC value and 9 because lung counting is not sensitive enough to determine 10 inta):es at areas of operational level, I know my plant would 11 be interested in looking at a 40 DAC hour internal action 12 limit. 13 (Slide) 14 HR. STANSBURY: I had mentioned--I will go through 15-this quickly, presuming on the knowledge of the panel. To 16 calculate a limit correaponding to a 3 rem effective dose 17 equivalent limit, one could start with a dose limit, use the 18 weighting factor, calculate the dose limit, the specific 19 effective energy from ICRP 30, use calculations for the 20 specific activity in the enrichment and come up with a derived 21 lung count limit. 22 Let me go through this, and this is in your 23 handout--3 percent, enrichment uranium we come up with an 24 answer of 345 micrograms of U235, which is what is measured in 25 the lung counter, and-- HERITAGE RFPORTING CORPORATION -- (202)628-4888
-74 1 CHAIRMAN MOELLER: Excuse me. What is the 3 rems ) 2 per_ year? Is that what you are applying? 3 MR. STANSBURY: The previous paragraph 20.205 said '4 for the list of radionuclides that licensees will be able to 5 control the exposure to worker on the basis of 3 rems '6 effective dose in a year. The idea is that would still leave 7 2 rems for external exposure and other contingencies. 8 CHAIRMAN MOELLER: Okay. Thank you. I didn't 9 recall that. 10 MR. STANSBURY: All right. 11 (Slide) 12 MR. STANSBURY: If we look from WASH 1151, and as (} 13 best we can glint off the chart, look at exposure, this was 14 done there again many, many years ago, which is a credit to 15 it, 325 micrograms is essentially the body burden limit that 16 we have had based on ICRP 2 methodology. 17 (Slide) 18 MR. STANSBURY: As far as impact, I would show this 19 slide to you. Can you all see that? Is it in focus? This is 20 essentially the weekly average airborne exposure in the 21 chemical area of the factory at Wilmington, the solid line, 22 the 13-week rolling average. This is in units where this 23 corresponds to the present maximum permissible concentration, 24 and that, by the way, is one thing that the present Part 20 25 will do is that it will get rid of this as a limit that is HERITAGE REPORTING COR"ORATION -- (202)628-4888
75 1 evil. .~. 12 I can appreciate the NRC staff member being 3 criticized for being, allowing workers to be exposed in excess 4 of the maximum permissible concentration. The derived air 5 concentration is in essence a reference level unless the DAC 6 becomes an NPC, a method for demonstrating compliance, and I 7 think you can see here the difficulty for the industry in 8 being able to comply with this and the expense that will be 9 necessary to drive exposures down below the DAC. 10 As far as cost estimates go, in 1982, Jack Faucett 31 and Associates in a study for the NRC talked about $28 million 12 to the uranium fuel fab industry, most of which were related {}' 13 to controlling internal exposure on the base of committed 14 dose. In 1985, there was an AIF study on a quarter of a 15 million dollars per facility to detect control on the basis of 16 lung counting, essentially an annual dose control. 17 In 1986, Westinghouse, another major fuel 18 fabricator, commented on the proposed 10 CFR 20 changes. They 19 presumed $15 million, but in their comments, they assumed that 20 they would not be able to use control on the basis of 21 committed effective dose. If you read their comments, that 22 assumption is obvious. And recently, we at GE have looked at 23 it and estimate six to ten million dollars for the GE facility l 24 to comply with committed dose control above and beyond what it 25 will take to implement the rest of those changes to Part 20. l HERITAGE REPORTING CORPORATION -- (202)628-4888
76 1 (Slide) rw i} 2 MR. STANSL'URY : I was asked to stay to about 15 3 minutes. I can stop here. 4 CHAIRMAN MOELLER: Go ahead. We are all right. 5 MR. STANSBURY: All right. I would then mention, 6 and maybe I have lost my chart. Where did the change come 7 from? ICRP 2 methodology considered the lung the critical 8 organ, and had a clearance time of 120 days of dose limit of 9 15 rems a year. ICRP 26 and 30 make a subtle change that has 10 a large impact. Besides dose to the lung, the ICRP 11 recommendations include dose to the lymph nodes and a small 12 . fraction of the uranium which is deposited in the lungs or 13 into their model is carried to the lymph nodes and retained CJg 14 with a half life of a thousand days or an infinite half life, 15 and this dose is integrated over 50 years, and that.is what is 16 responsible for the factor of 5 reduction. 17 The doses to the lung itself are not that much 18 different. Now why in their perspective they decided to make 19 that change, I don't know. I'm not sure that there was a l l 20 tremendous amount of evidence to do that. They may have done l 21 it for simplicity. It is tough to argue with the ICRP. They 22 don't meet over here very often and they don't like folks like l 23 me to come to their meetings. I appreciate you all letting me l l-l 24 come here. O i 25 If we get to looking, there is again some HERITAGE REPORTING CORPORATION -- (202)628-4888
=/- 77 ~1 operational data that I have done recently, and if we look at, . r-2 in our chemical area, we have both soluble and insoluble. forms 3 of uranium. If we went through and used ICRP 2, we calculate 4 essentially-assigned airborne exposure every day for each 5 worker in the area based on 350 air samplers throughout the 6 plant that are changed every eight hours and a time weighted 7 area system where each individual reports the areas where they 8 work, sophisticated air monitoring program. If we calculate 9 the lung contents going back about three years,-120 days as 10 the average retention time, then we can calculate a lung 11 contents. 12 We can also go in and measure the lung contents as () 13 an average lung count for a year. Each little X represents an 14 individual that works in the facility. In the ideal world 15 they would all lie on the reference line. Well, this isn't 16 the real world. As a result of internal goals, there are a 17 fair amount of spread in the numbers regardless of which way 18 that you look at them. The graph is important to us because 19 you will notice most of the dots lie above the line, and we 20 feel we are able to demonstrate that our sampling program is 21 representative. 22 That's not the subject for today. The subject for 23 today is, is if ICRP 26 and 30 were totally correct for 24 workers being exposed, then these dots would all lie down 25 here. There would be more uranium in the lungs because we are HERITAGE REPORTING CORPORATION -- (202)628-4888
78 i 1 talking about a 450 day retention time, not 120 day retention s 2 time, and there would be doses for many, many years ago from 3 this small amount that the models for the ICRP predict show up 4 in the lymph nodes driving these numbers still further this 5 way. Currently, there doesn't seem to be an exposure problem 6 with workers at our plant. However, if one assumes that there 7 is uranium in the lymph nodes, and integrates that over 50 8 years, one can indeed make a problem. 9 Thank you. 10 CHAIRMAN MOELLER: Thank ycu. Are there questions 11 for Mr. Stansbury? 12 MR. SHAPIRO: How much of a worker surveillance 13 program have you had over the years and have you noticed any {} 14 effect at all on workers in the lymph nodes or otherwise? 15 Is it lymphomas that you expect from uranium? 16 MR. STANSBURY: With working under the current NRC 17 limits which are based on ICRP 2, we would not expect to see 18 any effect in a worker population of 500 workers that has been 19 working for 15 years, so we really haven't looked for them. 20 In the work that I am familiar with at DOE 21 facilities, they have not found, and they have done extensive 22 epidemiology, they have not found untoward effects of exposure 23 to insoluble uranium. If there were any hope at all of 24 finding exposures, it might be worth looking for them, but at 25 current in the U.S. uranium industry, I am not aware of i HERITAGE REPORTING CORPORATION -- (202)628-4888
79 1 special surveillance for private industry. (- 2' MR. ALEXANDER: Bob Alexandria in NRC--Paul, has .3 your company made a decision yet as to whether or not to 4 continue in the fuel fabrication business if this derived air 5 concentration limit and intake limit is reduced by a factor of 6 5, ? 7 HR. STANSBURY: Okay. Let my start off by saying 8 that I am an engineer, and those decisions are made by 9 management, and I am not privy to the General Electric 10 Company's business decisions on that level. 11 However, if I might comment as someone who has been 12 involved through the low enrichment ucanium fuel fabrication 13 study group, the thing that I noticed is that uranium fuel 14 fabrication is a private industry, and it is under quite 15 intense price competition both domestically and also from 16 foreign manufacturers of fuel. 17 When one looks at the hassles that seem to be 18 typical of working with uranium in this country, and transfer 19 them to another country where the recommendations of the ICRP 20 are the same, but perhaps the vigorousness and the letter of 21 the law with which enthusiastic inspectors enforce the 22 regulations, it is a thought that there would be pressure to 23 move the production of pellets to an overseas facility. 24 Already one fuel fabricator has been bought by a 25 foreign concern. I'm not an expert at this, but it seems to HERITAGE REPORTING CORPORATION -- (202)628-4888
80 1 me it would be very easy.for them to move-their pellet () 2 manufacturing operations overseas, change their license to 3 ship the pellets in, put them into rods which is 4 radiologically a very clean environment, and move the uranium 5 fuel fabrication off-shore. I do not know what the General 6 Electric's policy is in this area. I do know from my 7-experience over the past three years that reducing costs is 8 scmething that we have been working at extremely diligently in 9 order to remain competitive in a world market. 10 Did I answer your question? 11 MR. ALEXANDER: Yes. 12 MR. CARTER: On that last graph you showed, it would 13 appear to me that you are overpredicting the amount of uranium 14 in the lung from air sample. Is that a fair assessment of the 15 data? 16 MR. STANSBURY: Yes. 17 MR. CARTER: You are doing it what, rather good or 18 rather poorly? My question really is how well do you measure 19 the amount of uranium in the lung by body counting? And the l~ 20 other one is how well do you measure by air sampling and then 21 predict? 22 In other words, were the problems in that as far as 23 the analytical side is concerned, in the air measurements and 24 the prediction, or are they in the measurement of uranium in 25 the lungs? l HERITAGE REPORTING CORPORATION -- (202)628-4888
e 81 1 MR. STANSBURY: Okay. - '() 2 MR. CARTER: You could have down the line 90-- -3 MR. STANSBURY: That is a terrible graph. I only 4 apologize a little bit. 5 The big number you see is 120 micrograms. Realize 6 now that the limit is out here at 325, so in-that respect, 7 these are all the exposures. We are very confident our 8 workers are nowhere near the limit, and that may not show from 9 this graph, but to me that's an extremely important sort of a 10 point, and we are essentially down around 30 percent of the 11 limit is where we do all of our monitoring. 12 MR. CARTER: I would expect the scatter to be a lot 13 less on the lower end of that curve than it is as the higher 14 end, yet I don't see that~at all. 15 MR. STANSBURY: Down around 50 micrograms is 16 essentially where the error is equivalent to the measurement, 17 and we have included measurements down here below 50 18 micrograms because we get numbers as they come out at best 19 estimate even though the, though the errors are large. 20 In the NESP study, they assessed the uncertainty of 21 lung count versus air sampling and lung counting came out to 22 within a factor of two or three if I remember correctly. That 23 is times or divided by two or three. Air sampling a factor of 24 5 is what they estimated was the best expectation you could 25 get from air sampling using the best available current s HERITAGE REPORTING CORPORATION -- (202)628-4888
82 1 techniques. [)) 2 MR. CARTER: That is based on a measurement and a 3 prediction then? I am trying to isolate where the problem is. 4 MR. STANSBURY: They just did an analysis of the 5 errors. No, it was not based on measurement and a prediction. 6 One of the questions is how do you' verify an air sampling 7 number? There are those that say the lapel samplers are the 8 way to go. My thought is that a lapel sampler only measures 9 the air that went in the lapel sampler. They also mention the 10 thumb print and the dust that gets sprayed on it. Hard to 11 tell. I haven't seen the study where people used 2 lapel 12 samplers. That would be a nice project for a student 13 somewhere. 14 MR. CARTER: Let me make sure I understand then what 15 you are saying on the graph here. These are based on air 16 measurements now then based on some kind of time averaging 17 where the people were working over some period of time? 18 MR. STANSBURY: This was data that I developed to 19 answer a question of an inspector how do I know that my air 20 sampling is representative? 21 MR. CARTER: It is still based on that? It is based l l 22 on a measurement and then-- 23 MR. STANSBURY: I did a measurement. 24 MR. CARTER: An estimate of when the people were 25 working in various areas and they are exposed presumably to HERITAGE REPORTING CORPORATION -- (202)628-4888 -~,,,- ,e-g --,_n r.- -e, - - -. -n,-- ,ww ,-n ~,--,4,w-,,.y ,y e--r-,--..-~,,en v-rr..~~ ,v+,,
83 1 varying concentrations of uranium and then they got some in m k_) 2 their body from various places and this presumably was counted 3 on an integrated basis or total. 4 MR. STANSBURY: Each measurement of essentially the 5 contents of the lung is based on well over a thousand 6-measurements suitably combined together, three years' worth of 7 back data, at least one air sample per day, sometimes many 8 more than that, combined in a weighted average. Lung counts 9 are typically four lung counts averaged together to get 10 average number for a year, and then the assumption of the ICRP 11 2 methodology 120 day retention time. 12 MR. CARTER: Let me ask the question another ay () 13 then. If a person is working in your plant presumably, they 14 might work on three or four different jobs or in three or four 15 different areas where the air concentrations I presume are 16 different. Otherwise you wouldn't need all these air samplers 17 if they were uniform. 18 MR. STANSBURY: Right. 19 MR. CARTER: If you got one data point up there with 20 representing an individual, how many measurements might that 21 represent in terms of say air concentration of uranium? 22 MR. STANSBURY: One to 3,000, 1,000 to 3,000 23 measurements; each X would represent for its position on the 24 absissa one to 3,000, 1,000 to 3,000 air sample measurements. 25 MR. CARTER: I still think we are talking about HERITAGE REPORTING CORPORATION -- (202)628-4888
84 1 different things. A guy working in your plant goes to work at (J-2 eight and he gets off at five. 3 Now what-kind of air samples, how many air samples 4 reflect the amount of uranium that he is exposed to say in one 5. day? 15 MR. STANSBURY: Okay. If he works at a grinder, and 7 he is there for six and a half hours as a grinder, there is an 8 air sampler located probably right about there that measures 9 the uranium in the area where he works. If he works back in 10 the chemical area, that might be a combination of 30 to 40 air 11 samplers that measure--a large room has centrifuges, 12 hydrolisis tanks and all sorts of apparatus that is weighted {} for the particular area that is his home base. 13 14 MR. CARTER: I presume maintenance Leople move 15 around a fair amount? 16 HR. STANSBURY: Right. They report which areas they 17 have worked in that particular day down to within a half an 18 hour, and we will run through and adjust the assigned airborne 19 exposure that they get depending on the particular time that 20 they turn in. 21 MR. CARTER: So there it really an awful lot of 22 averaging in that kind of number then? 23 MR. STANSBURY: Yes. 24 CHAIRMAN MOELLER: Okay. Well, thank you then. 25 MR. STANSBURY: Thank you for the opportunity. HERITAGE REPORTING CORPORATION -- (202)628-4888
85 L 1 CHAIRMAN MOELLER: Let me ask if the NRC staff wants () 2 to make any comments on this? 3 MR. WALTER COOL: I would have-liked to have asked 4 Paul'whether that last chart made any recognition of the 5 solubility of the uranium in the air? Because you do have a 6 mix across the plant from UF 6 and others to your grinder. 7 MR. STANSBURY: Generally we used the class D or the 8 class YNPC number, the current insoluble number, and the 9 reason is because in the chemical area most of the routine 10 material that is in the air is 95 percent class Y. It is only 11 when there are excursions particularly in the UF 6 areas, that 12 we see large amounts of class D material in the air, but if 13 you look at the studies of Cockwar and others that looked at 14 solubility in and around, essentially the uranium that is in 15 the air is for the most part class Y uranium with some class 16 D. 17 MR. WALTER COOL: In looking at your records, and 18 those of a number of other plants when we were doing the l 19 proposed rule, and you have pointed it out, you have got 20 people who work in there 10, 15 years, and they don't show 21 build-up in the lung that you would expect even under ICRP 2 22 methodology, which implies that the mix that they are 23 breathing is a lot more class D than class one. 24 MR. STANSBURY: I can show you the ceramic area 25 workers if you like, which is clearly all class Y. There HERITAGE REPORTING CORPORATION -- (202)628-4888
86 ll aren't as many points, which is why I didn't show it to you. r 2 Also it is more skewed to the current air sampling. There is 3 less long-term, so this is specifically for ceramic workers. 4 He was trying to save time, just show the one that looked thi 5 biggest, so this would not support the conclusion that there 6 is class D that is being cleared. This is class Y material, 7 and one can see again that the preponderance of points are on 8 the air sampling side'of the line, which shows that air 9 sampling with ICRP 2 methodology is currently providing some 10 -over estimation of lung contents, which is much easier to 11 defend than the other way. 12 MR. ALEXANDER: Bob Alexandria from NRC--Paul, the (} 13 conclusion that I believe might be drawn from your 14 presentation is that the NRC would do well to base its 15 regulations on in vivo counting as opposed to intake 16 radioactive material. 17 Is that the conclusion that you hope we would 18 derive? 19 MR. STANSBURY: Yes. I guess in fact it pleases me 20 that at least one person has come to the conclusion that I had 21 hoped to get to. 22 MR. ALEXANDER: For the record-- 23 MR. STANSBURY: Yes, I would very much like to see 24 the NRC recommend compliance based on lung counting in a 25 manner similar to the way it is done in the Department of HERITAGE REPORTING CORPORATION -- (202)628-4888
87 1 Energy facilities and is proposed in their draft Chapter 11. () 2 MR. SHAPIRO: Could you say a couple of words about 3 the reliability precision and accuracy of your lung counting? 4 What do you look for? This is for natural uranium? 5 MR. STANSBURY: This is for low enrichment uranium 6 up to, well, we have some enrichments up to pushing 5 percent, 7 but typical average is from 2 to 3 percent. 8 MR. SHAPIRO: What do you look for, what gamma ray? 9 MR. STANSBURY: Hundred and 85 key gamma ray from 10 U235. 11 MR. SHAPIRO: For natural uranium you really don't 12 have too much sensitivity, is that so? 13 MR. STANSBURY: Natural uranium, your sensitivity is 14 different. However, that's not something we have too much of 15 at fuel fabrication plants. We have a little. 16 CHAIRMAN MOELLER: Do you always work with precisely 17 the same enrichment? 18 MR. STANSBURY: No. The enrichment does vary. 19 However-- 20 CHAIRMAN MOELLER: How do you account for that in 21 the lung measurements? 22 HR. STANSBURY: It turns out if you go back to WASH 23 1151, because of the mix of isotopes, if you look down 24 here--get it straight here--if you look for the mix of 25 isotopes in this range, that's 5 percent; .7 is in here HERITAGE REPORTING CORPORATION -- (202)628-4888
88 1 somewhere. If you assume 3 percent, the function is fairly .,Q (_,/ 2 robust above that function. It has to do with relative ratio-3 of 238, 234 and 235. In the mixture, this was made on 4 specific particular assumptions. If one goes in and makes 5 other assumptions, you get a curve that is slightly different, 6 but it will be similarly robust. 7 CHAIRMAN MOELLER: Thank you. Other questions or 8 comments? Well, thank you once again. We will now go to Hal 9 Peterson. 10 MR. PETERSON: I would just like to say a few points 11 that so much as to go into what Mr. Stansbury said because I 12 think I covered that area before, but the first thing is the () 13 section 20205 that was deleted is the exception to NRC U 14 practice. The present rule, the present final rule and the 15 present existing rule are identical in the approach that they 16 took to handling long-lived radionuclides. The exception in 17 the proposed rule was in fact the exception of the three i 18 documents. That was a different concept. We have always 19 traditionally regulated on the committed dose, and in fact, i 20 mainly on the air concentration. l l i 21 The new Part 2022044 does permit not only the use of 22 specific body burden measurements or other methods of l 23 assessing other than air concentration alone to get a better l 24 estimate of body burden, but it also permits, and this is upon i 25 application to the Commission, the licensee to come in and \\ l HERITAGE REPORTING CORPORATION -- (202)628-4888
89 1 request a change of the derived air concentrations to () 2 specifically deal with whatever mixture or particle size or 3 whatever that the licensee may have. 4 In the proposed rule we did not require Commission 5 approval of this. We felt this was such a severe change to 6 allow them to use a limit other than the one we issue that we 7 one, wanted oversight. We did make it upon review, it is 8 possible then to come in and ask given a specific mixture, 9 composition and even solubility, for different, for a 10 different DAC to control exposures. 11 HR. CARTER: The way I read this, that the licensee 12 themselves could decide what procedure they wanted to use to 13 determine compliance, whether it be air sampling or whole body 14 counting or other methods. 15 MR. PETERSON: That is correct. 16 HR. CARTER: This was my reading of it. 17 MR. PETERSON: One change I didn't highlight when I 18 went through it the old change, the old part, proposed rule, 19 allowed you to change on the basis of bioassay results, change 20 an intake number that was assigned from air concentration if 21 the result would have been a higher dose or a higher intake, 22 but it didn't allow you to do it if it would be a lower 23 intake. 24 The new version allows the change in both directions 25 based on bioassay results, so in a lot of material that Mr. HERITAGE REPORTING CORPORATION -- (202)628-4888
90' 1 Stansbury presented showing the bioassay agreement with air I) 2 concentration, they could still take a count of.that in 3 adjusting for the air intake measurements on the new rule. 4 MR. CARTER: I don't know that he showed agreement. 5 I think he showed disagreement. 6 MR. PETERSON: The lackoof agreement, yes. The 7 other thing is I note that the NCRP 91 comment is quite, not 8 quite as severe on this issue. It says the NCRP notes that 9 the committed dose equivalent from long-lived intake of some 10 radionuclides of long effective-pardon me--lifelong intake of 11 some radionuclides of long effective half life would 12 overestimate by a factor of 2 or more the lifetime risks that (} 13 can be expressed equivalently. That's on page 19. But NCRP 14 also says the NCRP adopts the committed dose equivalent for 15 radiation protectfon planning such as in the design of 16 facilities and the development of manufacturing processes, 17 research protocols, et cetera, for demonstrating compliance 18 with those plans, and I think that that was close to 19 demonstrating compliance with our regulations, and for the use 20 and calculating annual limits of intake ALIs and derived air 21 concentrations, DACs. 22-The committed effective dose equivalent may also be 23 used to provide an estimate of the lifetime risk from a given 24 intake, and in this respect, its use is the same as the 25 effective dose equivalent for external radiation, and notes HERITAGE REPORTING CORPORATION -- (202)628-4888 =. - - _, -
91 1 the limitation on the long half life given above, so it says (). 2 it does not constitute sufficient basis in itself for the 3 evaluation of the potential health effects of radiation 4 exposures in individuals. 'And then they talk about actual 5 doses for that purpose, but I don't think, you know, that is a 6 legitimate use, so I just want to stress that as far as past 7 practice has been, the NRC, it has been fairly consistent with 8 the exception of the exception, and that is the thing that has 9 been different from the past procedure. 10 CHAIRMAN MOELLER: A couple of questions--you had 11 mentioned earlier that the National Cancer Institute would be 12 using certain cita for presumably epidemiological studies. /~\\ 13 HR. EETERSON: We don't have any firm commitment \\) 14 from NCI to do a study. They have expressed an interest in 15 that. They have also expressed some concern or very early on i 16 in the revision with the use of the effective dose ~ equivalent 17 concept because that essentially destroys the usefulness of 18 dose data for epidemiological purposes because you cannot tell 19 a 10 rem whole body dose from 300 rem thyroid dose when you 20 get a 10 rem effective dose, and we essentially noted to them 21 that the new form 5 that we will require for radiation data 22 reporting does have the, will require the filling out of both l I 23 the intake and/or body burden depending upon how it was 24 determined, and the nuclides, so that information would be t 25 there, and for that purpose, then we would be able to, one HERITAGE REPORTING CORPORATION -- (202)628-4888 r ,, _, _ _ _ _,,,, _~, . v _______..,.__..__,-.-,-,__,_,_m_m__..,,
.y 92 1 would be able to reconstruct some organ distribution. _ (R L Tj 2 CHAIRMAN MOELLER: Okay. Well, what will they do 3' with a committed dose equivalent? 4 MR. PETERSON: Very little. 5 CHAIRMAN MOELLER: You mean--well, how will they 6 know that the dose hasn't occurred? 7 MR. PETERSON: Primarily because it will be recorded 8 as to a committed does that year. So you know, that year the 9 dose will not have occurred. 10 I guess that the problem is if you got a uniform 11 exposure every year, you wouldn't have a pro'lem because the b 12 eventual dose equivalent that you get in the, near the end of /~N 13 the worker lifetime from situations where you get equilibrium 4 \\_) \\ 14 would be equivalent to just the intake. b 15 CHAIRMAN HOELLER: Well, I had heard people 16 discussing the use of committed dose equivalent in pointing 17 out that if you were doing an epidemiological study, and if J 18 you weren't careful in the dose, recorded dose information 19 that you used, you could be misled. 20 MR. PETERSON: Instead of effective dose in that / 21 case, what would be used would be the body burden. I think 22 that would be more useful. 23 CHAIRMAN MOELLER: What would happen--I see advances 24 hopefully continuing to come in technology and biology, et C / 25 cetera. If we reach a point and take.the presentation that we e e HERITAGE REPORTING CORPORATION -- (202)628-4888 l
93 1 have just heard where some representative sample method is ni_) 2 developed to remove uranium from the lung, what would you do 3-then with the committed dose equivalent?
- (
4 MR. PETERSON: I think if there were such 5 techniques, well. there are clearly--today it can be done by ],> 6 Lavin. That's not a conventional technique. You are talking i 7 about very simple chemical binding agent or with that 8 situation I think we would have to reconsider if that were to 9 be used. 10 CHAIRMAN MOELLER: And one last question that would 1 11 help us in terms of the Subcommittee's deliberations on this, 12 and we realize we wouldn't be deliberating if it was clearly (} 13 black and white, but you discussed, of course, among-the NRC al 14 staff and the different offices each were polled, or you know, 15 they were all brought in so that they all had input. <r 16 Was your decision on committed dose equivalent a 17 unanimous decision, or were there certain offices that would / 18 have preferred another approach? 19 In other words, is this a split decision or 20 unanimous decision? 21 MR. PETERSON: I think you are talking the removal 22, of 20.205. I don't think that there was any group in the NRC hi that was in favor of it, was there? 24 MR. DON COOL: This is Donald Cool, UMSS--I believe 25 the decision ended up being unanimous among the major offices t HERITAGE REPORTING CORPORATION -- (202)628-4388 s 4 ,4i~-
1 -94 1 CHAIRMAN MOELLER: ~Thak'b helpfui. TUunk you. . (,) 2 MR. PETERSON: I should add that -the pr:lucipal 9 3 proponent of that decision was Mr. Richard Cvginingham who i 4 happens to be the director of the division that licenses the 5 fuel material, so he is very sensitive to their p'oblem. r i 6 CHAIRMAN MOELLER: Any other questions for Hal 7 Peterson? 8 MR. SHAPIRO: I have a couple of questions we had 9 discussed earlier. I would just like the sense from the, your 10 staff and your department. I was really amazed to see that 11 the Roentgen was omitted from the definitions.since it is a s 12 unit on which all measurements of eqternal radiation are () 13 based, ionization of the air chamber, and we are going to do 14 this forever. Why did you throw it out? '15 MR. PETERSON: We threw it.out primarily because the 16 proposed rule--we, primarily was not used, iiisnotused 17 anywhere in the regulation. Where we specify a Roentgen 18 number, it is usually millirad, millirem. We don't use-- 19 MR. SHAPIRO: Yes, but-- 20 MR. PETERSON: Most instruments are calibrated. 21 MR. SHAPIRO: My own courses, the first thing I do, 22 what really saves me and my atudents really understand what is 23 going on is to quote from 13 CFR 20 for the definition of a rg 24 rad, and for the definition of the rad it says specifically V 25 the rad is, can be given in terms of Roentgen readings and HERITAGE REPORTIka CORPORATION -- (202)628-4888
I 95 1 that justifies a Roentgen and.is the main way we measure the 1() 2 rad, so when you throw that out, what'does one do as-far as 3 measuring the rad is concerned? Will we have to take our 4 Roentgen-readings in every specific case, convert to rad or 5 what do you expect people to do? 6 MR. PETERSON: I think we would normally do what I 7 do, and that's multiply the conversion factor, what is it, 87? 8 MR. SHAPIRO: You gave that status before. 9 MR. PETERSON: We gave a status by including--it was 10 in the proposed rule. Unfortunately, the proposed rule l' introduced a quantity called exposure meaning the sense of 1. being exposed to radiation as opposed to the official, quote, () 13 exposure which is the unit as the unit of the Roentgen, and we 14 went through things like even resurrecting the term exposure 15 dose which was an old term to try to keep both of these terms, 16 and it finally was decided that nobody liked keeping exposure 17 dose, and we finally sat down and said what is it used for? 18 Uned for the Roentgen. Do we need the Roentgen? And the 19 answer is it doesn't fall within the thing. 20 I would also point out tl.ere is no SI equivalent to 21 the Roentgen that I am aware of, and so that might be an 22 advantage fo-keeping the Roentgen. That is another story as 23 to whether we do that. 24 CHAIR! SAN MOELLER: Thank you, Hal. We have two 25 people here wno would like to make oral statements, and I will HERITAGE REPORTING CORPORATION -- (202)628-4088
96 1 call on them in alphabetical order--Bob Baker is first. '() 2 HR. BAKER: My name'is Bob Baker. I am representing 3 myself. I am an ex-NRCer,.and I was t&Jk leader on this 4 particular rule for about six, seven years, so I_know 5 something about the previous draft, but since I have not been 6 associated with this one, you have an advantage on this 7 particular one, but there are some other things going on which 8 may be helpful, and so I thought I would call these to the 9 attention of staff. 10 I am doing some work for DOE along very similar 11 lines, and the Department of Energy is about to come out with 12 three rules that are very closely associated with this-13 particu)7r rulemaking. Onc is one on occupational protection, [} 14 another one on environmental protection, and a third on 15 monitoring and surveillance. 16 These should be actually effective orders this fall, 17 by this fall, perhaps earlier. 18 Now the reason I r.ention these is because it is 19 -extremely timely since this rulemaking is still in the 20 process, and the rulemaking that we are working on, the order 2 21 making if you will, is also in a flexible mode, now is the 12 time to try to get our ducks lined up if we are to do so at 23 all. In other words, it would be awfully nice if all federal 24 agencies used the same dose conversion factors. It seems 25 strange that when three agencies have an identical exposure HERITAGE REPORTING CORPORATION -- (202)628-4888 .c..
97 1 situation that we-would get three different dose results. 1 2-There'is no reason for it, especially if the several agencies 3 are all in the process of making orders and regulations and 4 rules at the same time. 5 It is even less understandable when you consider 6 that in many cases, our prime sources are thu same persons, e 7 For example, we all lean very heavily on Oak Ridge National d Laboratories, certain individuals down there; in some 9 instances, PNL out in Washington and others. 10 We are all trying to implement ICRP 26 and 11 . subsequent publications, and like I say, it would be nice if 12 we could all use the same basic factors. (} 13 Now one factor which I would like to cite is a 14 factor of two that exists in the derived air concentrations or 15 other conversion factors in the appendix of the present Part 16 20. I know the factor at least was there in the previous 17 draft because I guess I was as responsible as aribody for 18 putting it there, and it was put there vith a rationale that 19 it would somewhat compensate for an age dependent parameter. 20 At the time it seemed like a good idea. Since that 21 time, it has lost a bit of its clamor really. I think in the 22 interests of trying to get uniformity among the several 23 different sources of air concentrations, et cetera, plus the 24 fact that there is an ongoing effort, a very great one, for 25 deriving age specific factors, it is time to drop the HERITAGE REPORTING CORPORATION -- (202)628-4888 - = - _ - -.
98 1 arbitrary-factor of 2, and if there are'any adjustments to,be I) 2 made, fine, make them as a side conversion rather than just 3 combining it in the entire table. So that would be my first 4 suggestion. 5 There are other, there are other factors which I 6 think it would be well for the various agencies to, to talk to-7 each other about. For example, the Q factors, et cetera, the 8 neutrons, this business of what can you use for the various 9 energies for your standards, for example, a hard gamma for 10 your RPDs or Qs or whatever, what to do with that and when. 11 We are all wrestling with the same problem, and we are all-12 going to have to use the best data available, but what is the /~T 13 best data and when do we start using it? V 24 I think again it would behoove the various federal 15 agencies te talk to each other. 16 I would like to say a few words about the topic of 17 annual dose versus committed dose, particularly with respect 18 to the exception which was in the last draft, and which I 19 understand has since been removed. 20 I think I as much as anyone disliked putting any 21 assumption in the last draft, and fought tooth and nail to 22 keep them pure of having anything like it. 23 We alt o made a great effort to go around and talk to 24 people in the field who have the problems. We talked to fuel 25 fab people. We talked to people who work with the plutonium HERITAGE REPORTING CORPORATION -- (202)628-4888
c: - 99 1 and other long-lived alpha' emitters, and we listened to them 'O (_j-2 and we walked in their facilities and watched them take air 3 samplers-and looked at their various counting mechanisms and 4 looked at their data until we were convinced, and this took 5 several days and a lot of pounding over my head particularly, 6 that there was insufficient data at least at that time to give 7' us the confidence that they could demonstrate that they were 8 in compliance with a dose commitment that would be equal to 9 the annual limit, effective dose equivalent limit. 10 Now you take the case of uranium. Paul mentioned i 11 some of the parameters. I am going to hammer both sides of 12 the fence now. I can do this because I am representing 13 myself. ) 14 I don't think that the people out there that are 15 taking the measurements of the air and the biological 16 measurements have an adequate fix to really ba certain as to 17 how much material is in these people at any particular time or 18 the form that it is in or the rate at which it is coming out 19 or the rate at which it is going in. 20 In othar words, I think it as a transient situation 21 and they don't have an adequate number of measurements that 22 have a firm grasp on just what might be the dose or where that 23 might reside, whether it is lungs, or the bone or where or 24 t'he r e. 25 On the other hand, put yourself in the regulatcr's HERITAGE REPORTING CORPORATION -- (202)628-4888
L 100 1 position. Let's suppose that using relatively reasonable but f~~ 2 somewhat conservative assumptions, one calculates a dose from 3 an annual intake, and you are guesstimating it might be 25 rad 4 effective dose equivalent from one year's intake. Now what do 5 you do? Do you fine them for overexposure? Do you remove 6 the person from work for a while, or what or what or what? It 7 is what action do you take? 8 Now let's suppose you took some action, whatever it 9 might be, and then two quarters later, based on better data, 10 one finds that no, instead of being 30 or 50 or whatever you 11 had calculated that to be, it really looks more like 3. Now 12 what do you do? Hand the man his fine back? Say sorry out () 13 that. Didn't mean to inconvenience you for restricting that 14 worker's work, and by the way, that wasn't really an 15 ove exposure that you reported? And so it goes. You can see 16 the numerous problems that you get into of the uncertainty of, 17 imprecision of just what that dose is over 50 years period of 18 time when you are trying to make that estimate on what you 19 know today or even tomorrow or next year. 20 Now in addition to that, of course, it is true that 21 DOE has workers doing the same sort of thing, that is, that 22 are indeed working from body burdens and the best information 23 that they can and working on an annual dose. 24 On the other hand, they also, they also are looking 26 at what might be the committed dose from that, and if you go HERITAGE REPORTING CORPORATION -- (202)628-4888
101 1 back and look at the exception that was in the previous draft, ([ 2 .it also called for looking at what might be the committed dose 3 as well as permitting the annual dose, so you see, we were i 4 trying to really bridge that gap. 5 Now what'we were hoping at the-time was that in 16 five, ten years perhaps, there would be an adequate amount of 1 7 data that we could all share the good feeling that yes, we -8 didn't need the exception, and we move it and here is the data 9. that would allow us to do it. Now I don't know about that 10 data base that exists. Perhaps the NRC could point out just 11 where it is that they found the data base that permits the 12 accurate 50 years committed calculations that would permit 13 them to say that yes, indeed, you were within five and you .} { 14 weren't at six or ten and it is not going to change next year 15 from that intake that we had this year. 16 Well--and also think of the complications that you 17 have normally from going from government facilities to 18 licensed facilities and back and forth. 19 Well, I guess I have taken my fair amount of time. I 20 I would like to point out that the EPA in their final 21 rulemaking on the occupational exposure does permit the annual i 22 dose. As a matter of fact, it is my understanding reading the 23 rule that the doses that people actually do have may be 24 handled that way. In other words, that burden that they are O 25 carrying are calculated annually, and that's the dose that is l 1 HERITAGE REPORTING CORPORATION -- (202)628-4888 - = - - - -
102 1 carried along. I) 2 Now I think it is fine to also list the dose and 3 forget it. I hope some day we won't have anything but the 4 committed dose, but frankly, I don't know that day. 5 One other comment, I think that the answer to the 6 question of why does it take so long to get a rule like this 7 through, it is not that we couldn't have done it technically 8 half a dozen years ago. There are a lot of tough decisions 9 that come about politically because of controversial issues 10 and nobody wants to decide whether we want to kill the thing 11 or give to a green light and push it along, and so the best 12 thing to do is to put a caution light up and just let it sort 13 of drag along until another agency comes along and forces the (~)T - N. 14 issue, and I think very much that's the case here. 15 Thank you very much. 16 CHAIRMAN MOELLER: Thank you, Bob. I might mention 17 that repeating what Bob said in his opening remarks, we had 18 enjoyed his summaries of this same topic over the years and 19 his work on it. 20 The other person who wants to speak is Allen 21 Richardson from EPA, and let me mention and put in the record 22 that he has provided us copies of the January 1987 standards 23 guidance signed by the President on radiation protection 24 guidance to federal agencies for occupational exposures, and 25 we want to thank him for these, for these copies. HERITAGE REPORTING CORPORATION -- (202)628-4888
103 1 MR. RICHARDSON: ~ Thank you, Dr. Moeller. I just () ,2 have four brief comments to make. The first one is extremely 3 brief. 4 I would just like to say I am somewhat puzzled by 5 Mr. Stansbury's comment about the possible flight of the U.S. 6 industry in fuel fab to Europe because Europe is now by and 7 large all operating under the same kind of rules that the NRC 8 has been-proposing here today--the use of committed dose for 9 controlling internal medical. 10 My second point has to do with what I hope may be 11 useful perspective on this, this thor ny issue of--I would like 12 to point out that the argument is really about dosimetry. 13 models, not about the level of protection, and it is not about ( 14 the use of committed dose, either. The old MPC s were based 15 on the concept of committed dose. They tracked the dose that 16 would pile up in somebody's body tver a period of 50 years as 17 constant level of intake. They required the same kinds of 18 calculations that committed dose requires. In fact, the 19 values are numerically identical and you can write down the 20 theorem which shows that they are, so we are not, the 21 discussion is not about the use of committed dose. 22 The discussion is really about metabolic models, 23 what has happened? Well two things have happened. One thing j 24 that has happened is the new proposed standards are three O 25 times more relaxed in terms of protection than the old ones. I HERITAGE REPORTING CORPORATION -- (202)628-4888
104 1: Where the old ones were based on 15 rems to the lung, the new f3 's_/. 2 ones are based on weighting factor which is equivalant to 42 3 rems to the lung. It is approximately three times more dose 4 to the lung. 5 So the standards in this particular case, have 6 actually been relaxed in terms of dose to the lung. 7 What has changed in the other direction is the 8 metabolic modeling. It has gotten fifteen times worse so the 9 net effect is five times lower MPC s, ALIs, derived air 10 concentrations, or whatever you want to call them. 11 I think it is interesting to point out the situation 12 would have been much worse if we didn't go to the ICRP (} '13 effective dose situation. It would be three times worse, we 14 would still be stuck presumably with the scientific evidence 15 that says that the old models are wrong, and we would still 16 have to deal with whatever the dose limit was, either 15 rems 17 to the lung or 5 rems effective dose. That's all I have to 18 say about that one. 19 I have some remaining concern about the application 20 of the federal guidance to this problem. It is a messy 21 question, and the answer provided in the federal guidance is 22 not entirely lucid. What the federal guidance says is that 23 the control of radionuclides should be based on committed 24 dose. It then goes on to say that when that control fails, 25 then appropriate precautions should be taken to make sure that HERI? AGE REPORTING CORPORATION -- (202)628-4888
105 1 the worker's dose does not exceed 5 rems in any year because ([ 2 of accumulation in the body. -Presumably, for example, 3 somebody.could violate the com.nitted dose limit of 5 rems and 4 end up with a 12 rem annual dose with a severe overintake, and 5 the intent of the federal guidance is that the annual dose 6 should be used for those workers who have exceeded the 7 committed dose limit to monitor their annual doses to make 8 sure that they don't exceed the 5 rem limit on an annual' 9 basis. 10 It is a protective mechanism for situations in which 11 the control of the workplace fails, and for those workers 12 only. 13 One last very small comment--Bob Baker made a plea [} 14 for uniformity among the federal agencies, and I would like to 15 report to you that we are hoping to make a start in doing that 16 not just through the federal guidance on occupational exposure 17 but also on dose conversion tables. The Departments of 18 energy, EPA and the NRC are beginning a cooperation this 19 summer with Oak Ridge to put out uniform sets of dose tables 20 tha*. We hope everybody will be able to use. 21 Thank you. 22 CHAIRMAN MOELLER: Thank you. Okay. That unless 23 there are-- 24 MR. SHAPIRO: I have just one more. I have to bring 25 this up. This is a point that sort of is written off very HERITAGE REPORTING CORPORATION -- (202)628-4888
106 g 1 lightly in your comments, and yet is' throwing the whole () 2 academic community into a real trauma. This is a problem with 3 the way the NRC enforces security of radionuclides, and you 4 have, you have a, you have written a clause in 10 CFR 20 5 saying that radioactive material secured from unauthorized 6 removal or access, and unless you do something to clarify what 7 you mean as to what level you secure from unauthorized 8 removal, any trivial amount of radioactivity in the laboratory 9 has to be kept under lock and key with the NRC inspectors. 10 An'd most of the time spent by our radionuclied 11 committees, now radioisotopes committees now, are on this 12 question. The professors are just going really wild trying to 13 figure out how to comply with this. Overenthusiastic j 14 inspectors will cite you all over the place. They are 15 building many research laboratories now where the lab is, 16 laboratories are open. The building itself may cr may not be 17 secured, but they don't put a door on every single laboratory. 18 It is difficult to see how to comply with this, and although I 19 know it will take perhaps some thought to actually meet the 20 goal of the standard and still allow the community to comply 21 with it, I think that there should be some addressing to this 22 particular point. 23 I noticed that in the case of labeling, that you do 24 exempt small quantities from labeling. You may be able to put l 25 some cort of an exemption into this, but it is not, it is not 1. HERITAGE REPORTING CORPORATION -- (202)628-4888 - - - ~ . ~.
r 107 .1 a trivial point. Your comment said that locking radiotracer () 2 not being used is a small nusance compared to the consequences 3 of unauthorized access. I would like to say that it is not a 4 small nuisance. It is a main concern now, and really 5 something that has to be looked at. 6 MR. ALEXANDER: Jake, I have heard a number of 7 professors over the past year remark that in many of the 8 universities, research institutions, that because of problems 9 likt this, there is an attitude now that if there is any way, 10 any other way to do it other than using radionuclides, it 11 would be done that way. 12 Is that the direction we-are going? 13 MR. SHAPIRO: No question, no question that between {} 14 the cost of waste disposal, the cost of security, and in some 15 cases, harassment by inspectors, it is really not a lot of fun 16 to use radionuclides anymore, so I think these standards have 17 to be clear on intent. 18 CHAIRMAN MOELLER: Thank you, Jack. Any other 19 comments or questions? 10 MR. DON COOL: I have one comment. This is 21 done--not to beat a dead horse perhaps, but the factor of 2 22 that has been brought up on several occasions, and I think 23 your Subcommittee should be aware that this was a peint of 24 long discussion within the staff's working group, and l ( 25 oversight group both. The factor of 2 does have credence in HERITAGE REPORTING CORPORATION -- (202)628-4888
108 1 an ICRP statem^nt, I believe 1985 statement, although I'm not ( ). 2 sure exactly which one, for general adjustment.for younger 3 children, so there is credence to the particular use of the 4 factor of 2. 5 Taking out such a factor would implicitly assume 6 that we give credence to a factor of one, that is, there is no 7 difference between adults and children or others who may be 8 present in the population, and the question then faced by the 9 staff was do we use recognizably inaccurate factor such as a 10 factor of 2 because we are aware there are differences in 11 radiosensitivity, and because we realize that adjustments 12 would as a generalization increase that adjustment you would {} make in the dose for younger children or infants? 13 14 There is work going on which would give you a whole 15 series of factors, and it goes up from one, to an adult up to 16 40 and 50 in some cases preliminary work floating around. Do 17 we use some number greater than one recognizing it is 18 imprecise, or do we make no adjusteent whatsoever, and 19 implicitly say we are not going to provide any additional 20 protection? We recognize you are out there, but we are not 21 going to do anything. 22 The staff concluded that it needed to take some step 23 recognizing the trauma, recognizing that it is a, it comes 24 down the road, this also provides a mechanism to go back in 25 and modify to when such factors become available. HERITAGE REPORTING CORPORATION -- (202)628-4888
e 109: 1 CHAIRMAN MOELLER: _Thank you. Once again, anymore D) (_ 2 comments? Any' questions? 3 MR. CARTER: Let me mention one thing. Several 4 people have mentioned the metabolic and symmetric business 5 essentially,-and it would appear to me that it is sort of .6 going toward essentially the use of Keith Erickerman at Oak 7 Ridge not only by the various federal agencies, but ICRP and 8 so forth. 9 Of course, there is an awful lot of people that are 10 involved in developments in this area, and I think we better 11 be very careful in not being entirely dependent on, you know, 12 sort of one place to do this. I think somehow or other we 13 need a check and balance system as good as Keith Erickman is. ( }- 14 There is still an awful lot of people around the world that is 15 working in the area, and I think there will be evolution in 16 this just like everything else, so new data basically come out 17 periodically in the area, so I would just be very cautious and 18 not standardize or get frozen on a single set of values, and 19 even recognized as far as additional work. 20 MR. ALEXANDER: There was, a point was made earlier 21 about the necessity and desirability of interagency 22 coordination in matters such as how to calculate internal 23 dose. 24 I would like to point out that considerable 25 coordination takes place in the area of radiation protection HERITAGE REPORTING CORPORATION -- (202)628-4888 J
110 1 -health effects through the CIRRPC organization, for example, () 2 the question of the quality factor for neutrons. We have 3 worked together for about two years on that problem, and the 4 question of how to calculate doses, and coordinating that 5 could I think easily be handled and perhaps handled very well 6 through CIRRPC, so we do have available to us that 7-organization for interagency coordination on these matters. 8 CHAIRMAN MOELLER: Bob, did you want to comment? 9 MR. BAKER: Just wanted to add on to this comment 10 with respect to Keith Erickman, he is almost the sole source 11 worldwide. He is almost the worldwide treasurer, although I 12 would hate to have him hear that. It turns out that at least () 13 as of a couple of years ago there wasn't any duplicate 14 facility or capability anywhere else in the world, and he has 15 been doing the calculations for the world and they could spot 16 check him on a few places here and there, particularly in the 17 UK, but only spot checking. It was not duplication of the 18 entire spectrum of calculations, so I am afraid he is kind of 19 a one and only. 20 Thank you. 21 HR. CARTER: It is even a little worse than that. 22 Not only does he know it, but a lot of what he knows isn't 23 down on paper yet, so you better hurry up and get at it! 24 MR. BAKER: He is not talking. 25 CHAIRMAN MOELLER: Okay. With that, we will-- HERITAGE REPORTING CORPORATION -- (202)628-4888
111 L 1 MR. RICHARDSON: I will make it very brief--there is I 2 some other input getting into the system. Koretski from 3 Germany has pointed out some of the problems in current 4 calculations which Keith io now working on. There are other 5 countries looking at;this thing, and also that the 3 6 Japanese--Japanese do everything. In this case they are now 7 setting up to make calculations based on ICRP independently 8 themselves, and they are going to be checking up on Keith's 9 numbers. 10 One last comment if I may on this question of factor 11-of 2--taking children into increased sensitivity, children I r 12 into account, I think it is very risky business. We don't put (} 13 a factor of .2 in for old people, and I think the difficulty 14 arises because we always think in terms of annual dose, but we 15 are protecting populations. We are really protecting people 16 over a lifetime. 17 We always make the assumption that they could be 18 there for their whole lifetime and the risks that are probably 19 most applicable to the exercise are the average risks over a 20 whole age span from birth to death, and because of that, maybe 21 it isn't appropriate to put in age specific corrections into 4 i 22 annual doses when they are being used for protection of I 1 C' populations. 24 CHAIRMAN MOELLER: Thank you. I believe with that t 25 then, one more try, we will say that we have wrapped up the HERITAGE REPORTING CORPORATION -- (202)628-4888
112 1 formal session of this Subcommittee meeting for 10 CFR 20. We () 2 will recess for lunch, and then we will reassemble for an l 3 Executive Session this afternoon beginning at one o' clock in 4 which we will try to set down some written comments which will-5 be forwarded to the full ACRS for its consideration and its 6 monthly meeting this week, and then hopefully at that meeting. 7 they will issue a letter to be cent to the NRC Chairman with a 8 summary of the Full Committee's comments. 9 MR. MICHELSON: Let me ask were you going to use 10 this room this afternoon? 11 CHAIRMAN MOELLER: Okay. No. I think there is 12 another subcommittee that will be meeting in here, and I am 13 told there is still another group meeting in the Chairman's (} 14 office, so we will be off somewhere in some room for our 15 Executive Session. Anyone who wants to sit and listen, you 16 are welcome to do so. I'm sure out at the guard's desk they 17 can tell you where we are. Walk up and down the halls until 18 you find us. 19 Well, thank you. Thanks especially to our members 20 of the public, Paul Stansbury and Allen Richardson and Bob 21 Baker for joining us and sharing with us their thoughts, and 22 thanks as always to the NRC staff for their patience and 23 coverage of a tough topic. With that, I will--and thank our 24 reporter. 25 With that, we will call this meeting adjourned. HERITAGE REPORTING CORPORATION -- (202)628-4888
113 j 1. < 1 (Whereupon, at 11:56 a.m., the meeting was 2 adjourned.) 3 i 1 l \\ l 4 i. 5 i l 1 6 7 l 8 l l i 9 l l 10 l l 11 1 12 I f + 14 i I 15 t 16 i f 17 h 18 l. 19 j 20 21 i l 22 23 l 25 HERITAGE REPORTING CORPORATION -- (202)628-4888
1 CERTIFICATE () 2 3 This is to certify that the attached proceedings before the l 4 United States Nuclear Regulatory Commission in the matter of: 5 Name: ACRS--Subcommittee on Occupational and Environmental Protection Systems 6 7 Docket Number: 8 Place: Washington, D.C. 9 Date: May 31, 1988 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, thereafter reduced to typewriting by me or under the direction 13 14 of the court reporting company, and that the transcript is a ) true and accurate record of the forego 1 g proc edings. 15 16 /S/ M W / 17 (Signature typed): Catherine S. Boyd 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25 O Heritage Reporting Corporation (202) 628-4888
o n p Concentrationbr. ts for Release to the G:neral Environment f (unrestricted areas) (microcuries per millimeter) t I Air Water Radionuclide Change Change Former Revised (Direction Former Revised (Direction Part 20 Part 20 & Factor) Part 20 Part 20 & Factor) [ Tritium (Hydrogen-3) 2x10 7 (I,5) 7x10 8 42.8 3x10 3 (I,5) 1x1C 3 43.0 [ l j Cobalt-60 3x10 10 (I) 2x10 10 41.5 3x10 5 (I) 3x10 6 (I) 410.0 Krypton-85 3x10 7 (Sub.) 7x10 7 t2.3 l Strontium-90 3x10 12 (S) 3x10 11 NC 3x10 7 (S) 4x10 7 tl.3 Ruthenium-106 2x10 10 (I) 1x10 10 42.0 1x10 5 (I,5) 3x10 6 43.3 i Iodine-131 1x10 20 (S) 2x10 10 t2.0 3x10 7 (S) 1x10 6 t3.3 l i l Xenon-133 3x10 7 (Sub.) 5x10 7 tl.6 r Cesium-137 5x10 1 (I) 2x10 10 42.5 2x10 5 (S) 1x10 6 420. Radium-226 3x10 12 (S) 9x10 13 43.3 3x10 8 (S) 7x10 8 t2.3 l t Thorium-232 1x10 12 (S) 4x10 ts 4250. 2x10 6 (S) 3x10 8 467. Uranium-238 3x10 12 (S) 3x10 12 NC 4x10 5 (S) 3x10 7 4133. Plutonium-239 6x10 14 (S) 2x10 14 43.0 5x10 6 (S) 1x10 7 450. l Americium-241 2x10 13 (S) 2x10 14 410. 4x10 6 (S) 3x10 4133. j I f l I I - Insoluble S - Soluble Sub - Submersion dose NC - No Change (1) { l }
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Q Tuesday January 27,1987 i 0 I O Part 11 The President l Radiation Protection Guidance to Federal Agencies for Occupational Exposure; l Approval of Environmental Protection l l Agency Recommendations t ( O F der R gister of 'ri a), ja uar) 30 d \\Ve nesday, February 4,1987.]
2822 pFederal Register Presidential Documents ( Vol. 52. No.17 Tuesday. january 27, 1987 Title 3-Recommendations Approved by the President The President Radiation Protection Guidance to Federal Agencies for Occupational Exposure The recommendations concerning Federal radiation protection guidance for occupational exposure transmitted to me by the Administrator of the Environ-mental Protection Agency in the memorandum published below are approved. I direct that this memorandum be published in the Federal Register. To promote a coordinated and effective Federal program of worker protection, the Administrator is directed to keep informed of Federal agency actions to implement this guidance and to interpret and clarify these recommendations from time to time, as necessary, in coordination with affected Federal agen-cies. Consistent with existing authority, the Administrator may, when appro-priate, consult with the Federal Coordinating Council for Science, Engineering and Technology. The Administrator may also, when appropriate, issue inter-pretations and clarifications in the Federal Register. Approved: January 20,1987 O Mk blhng rode 319541-M hiemorandum for the President FEDERAL RADIATION PROTECTION GUIDANCE FOR OCCUPATIONAL EXPOSURE This memorandum transmits recommendations that would update previous guidance to Federal agencies for the protection of workers exposed to ionizing radiation. These recommendations were developed cooperatively by the Nu-clear Regulatory Commission, the Occupational Safety and liealth Admints-tration, the hiine Safety and liealth Administration, the Department of De-fense, the Department of Energy, the National Aeronautics and Space Admin-istration, the Department of Commerce, the Department of Transportation, the Department of liealth and lluman Services, and the Environmental Protection Agency. In addition, the National Council on Radiation Protectian and hieas-urements (NCRP), the National Academy of Sciences (NAS), the Conference of Radiation Control Program Directors (CRCPD) of the States, and the flealth Physics Society were consulted during the development of this guidance. l Executive Order 10831, the Atomic Energy Act, as amended, and Reorganiza-tion Plan No. 3 of 1970 charge the Administrator of the Environmental Protection Agency (EPA) to " advise the President with respect to radi-ation matters. directly or indirectly affecting health, including guidance for all r' s Federal agencies in the formulation of radiation standards and in the estab-lishment and execution of programs of cooperation with States." This guid-ance has historically taken the form of qualitative and quantitative "Federal Radiation Protection Guidance." The recommendations transmitted here would replace those portions of previous Federal guidance (25 FR 4402), approved by President Eisenhower on hiay 13,1960. that apply to the protec-
Federal Register / Vol. 52, No.17 / Tuesday, January 27, 1987 / Presidential Documents 2823 tion of workers exposed to ionizing radiation. The portions of that guidance which apply to exposure of the general public would not be changed by these 3 recommendations. ~ These recommendations are based on consideration of (1) current scientific understanding of effects on health from lonizing radiation, (2) recommenda-1 tions of international and national organizations invoivad in radiation protec-g tion (3) proposed "Federal Radiation Protection Gu'dcoce for Occupational g Exposure" published on January 23,1981 (46 FR 7836) and public comments on M that proposed guidance, and (4) the collective experience of the Federal y agencies in the control of occupational exposure to ionizing radiation. A 3 summary of the considerations that led to these recommendations is provided _g below. Public comments on the previously proposed guidance and a response to those comments are contained in the document "Federal Radiation Protec-7 tion Guidance for Occupational Exposure-Response to Comments" (EPA 3 8 520/1-84-011). Single copies of this report are available frem the Program hianagement Office (ANR-458) Office of Radiation Programs, U.S. Environ-k mental Protection Agency, Washington, D.C. 20460: telephone (202) 475-8388. m N
Background
w A review of current radiation protection guidance for workers began in 1974 ] with the formation of a Federalinteragency committee by EPA. As a result of 1 the deliberations of that committee EPA published an "A-lvance Notice of E Proposed Recommendations and Future Public liearings" on September 17, i 1979 (44 FR 53785). On January 23, 1981. EPA published "Federal Radiation Protection Guidance for Occupational Exposures: Proposed Recommenda-tions, Request for Written Comments, and Public Hearings" (48 FR 7836). = Public hearings were held in Washington, D.C. (April 20-23, 1981); Houston, j Texas (hf ay 1-2, 1981): Chicago, Illinois (hiay 5-6, 1981), and San Francisco.g a California (hiay 8-9,1981) (46 FR 15205). The public comment period closedW 2 July 6,1981 (46 FR 26557). On December 15,1982, representatives of the ten Federal agencies noted above, the CRCPD, and the NCRP convened under the sponsorship of the EPA to review the issues raised in public comments and to complete development of these recommendations. The issues were carefully J considered during a series of meetings, and the conc.usions of the working g group have provided the basis for these recommendations for revised Federal guidance. EPA has also sporssored or conducted four major studies in support of this q J review of occupational radiation protection guidance First, the Committee on the Biological Effects of lonizing Radiations, Nationel Academy of Sciences-National Research Council reviewed the scientific data on health risks of low levels of ionizing radiation in a report transmitted to EPA on July 22, 1980: "The Efiects on Populations of Exposure to Low Levels of lonizing Radiation: 1980," National Academy Press Washington, D.C.1980. Second, EPA has published two studies of occupational radiation exposure "Occupational 2 Exposure to lonizing Radiation in the United States: A Comprehensive Sum-I = mary for the Year 1975" (EPA 520/4-80-001) and ' Occupational Exgosure to 4 lonizing Radiation in the United States: A Comprehensive Review foi the Year 1980 and Summary of Trends for the Years 1960.-1985" (EPA 520/1-4-005). Third, the Agency sponsored a study to examine the changes in predously derived concentration limits for intake of radionuclides from air or water that result from use of up-to-date dosimetric and biological transport models. 1 These are presented in Federal Guidance Report No.10. "The Radioactivity Concentration Guides: A New Ca!culation of Derived Limits for the 1960 Radiation Protection Guides Reflecting Updated hiodels for Dosimetry and Biological Transport" (EPA 520/1-84-010). Finally, the cost of implementin the changes in Federal guidance proposed on january 23,1981 was surveyet and the findings published in the two-volume report: "Analysis of Costs for Compliance with Federal Radiation Protection Guidance for Occupational Exposure: Voh.me I-Cost of Compliance"(EPA 520/1-83-013-1) and "Volume ? Il-Case Study Analysis of the impacts" (EPA 520/1-83 4 13-2). These EPA
w 1 2324 Federal Register / Vol. 52. No.17 / Tuesday, Januap 27, 1987 / Presidential Documents m ~ reports are available from National Technical Info matioa Service, U.S. De-partment of Commerce, 5285 Port Royal Road, Spnngfield, Virginia 22101. { j The interagency review of occupational radiation panection has confirmed the need for revising the previaus Federal guidance, which was promulgated in _j 1960. Since that tirae knowledge of the effects of ionizing radiation on humans has increased substantially. We now have a greatly improved ability to estimate risk of harm due to irradiation of individual organs and tissues. As a ~ result, some of the old numerical guides ate now believed to be less and some ig more protective than forrrerly. Other risks, specifically those to the unborn, are now considered to be more signficant and were not addressed by the old C guidance. These disparins ano omissions should be corrected. Drawing on i this improved knowledge, the International Commission 'on Radiological Pro-tection (ICRP) published, in 1977, new recommendations on radiation protec-tion philosophy and limits for occupational exposure. These recommendations are now in use, in whole or substantial part, in must other countries. We have r considered these reco nmendations, among others, and believe that it is P appropriate to adopt the geaeral features of the ICRP approach in radiation protcction guidance to Federal agencies for occupational exposure. In two '=-- i cases, protection of the unborn and the management of long term exposure to internally deposit.d radioactivity, we have found it advisable to make addi. E
- tions, v
[ There are four types of pos,ible ofrects on health from exposure to ionizing radiation. The first of these is mncer. Cancers caused by radiation are not g lik different from those that have been historically observed, whether from known or unknown causes. Although radiogenic cancers have been observed rE in humans over a range of higher doses, few useful data are available for defining the effect of doses at normal occupational levels of exposure. The second type of effect is the induction of hereditary effects in descendants of = exposed persons. The severity of hereditary effects rcnges from inconsequen. v tial to fatal. Although such effects have been observed h experimental h animals at high doses, they have not been confirmed in studies of humans. F-Based on extensive but incomplete scientific evidence,it is prudent to assume that at low levels of exposure the risk of incurring either cancer or hereditary effects is !!nearly related to the dote received in the relectat tissue. The severity of any such effect is not related to the amount of dose recei"o;. That is, once a cancer or an hereditary effect has bien induced, its seventy is r independent of the dose. Thus, for thee two types of effects, it is assumed that there is no completely risk free level of exposure. I-The third type includes a variety of effects foi which the degree of damage (i.e., severity) appears to depend on the amount of dose n.ceived and for which there is an effective threshold below which clinically observable effects do not occur. An example of such an effect is radiation sickness syndrome. which is observed at high doses and is fatal at very high doses. Examples of lesser effects include opacification of the lens of the eye, erythema of the skin. e and temporary impairment of fertility. All of these effects occur at relatively high doses. At the levels of dose contemplated under both the previous Federal guidance and these recommendations, clinically observable examples j-of this third type of effect are not known to occur. The fourth type includes effects on children who were exposed in utero. Not only may the unborn be more sensitive than adults to the induction of malformations, cancer, and hereditary effects, but recent st adies hee drawn T-renewed attention to the risk of severe mental retardatica from exposure of Z the unborn during certain periods of pregnancy. The risk of less severe mental retardation appears to be similarly elevated. Although it is not yet clear to what extent the frequency of retardation is proportional to the amount of dose (the data available at occupational levels of exposure are limitedl. it is prudent to assume that proportionality exists. The risks to health from exposure to low levels of ionizing radiation were reviewed for EPA by the NAS in reports published in 1972 and in 1980.
Federal Reg! ster / V:1. 52. N:.17 / Tu:sday, January 27, 1987 / Presid:nti:1 Documents 2825 Regarding cancer there continues to be divided opinion on how to interpolate between the absence of radiction effects at zero dose and the obs of radiation (mostly at high dosq to estimate the most probable effetts e bw i: doses. Sorre scientists bolleve llad available data best support use of a irtaar model for estimating such effects. Others, however, believe that other models, which usually predict somewhat lower risks, provide better estimates. These differences of opinion have not ben resolved to date by studies of the effects of radiation in humans, the most important of which are those of the Hiroshi. ma and Negasaki atom bomb survivors. Studies are now underway to reas-sess radiation dose calculations for these survivors and in turn to provide improved estimates of risk, it will be at least several years befote these reassessments and estimates are completed, and it is not likely that theysvill conclusively resolve uncertainties in estimating low dose effects. EP/ ls monitoring the progress of this work. When it is completed we will initiate reviews of the risks oflow levels of Mdiation,in order to provide the basis for any indicated reassessment of this guidance. in spite of he above uncertainties, estimates of the risks from exposure to low t I, levels of 10 nzing radiation are reasonably well bounded, and the avirage 5 Worker is believed to incur a relatively small risk of harm from radiation. This situation has resulted from a system of protection which combinos limi s on F maximum dose with active application of measures to minimize doses within f' these limits. These recommendations continue that approach. Approximately 1.3 million workers were ernployed in occupations in which they were poten-tially exposed to radiation in 1980, the latest year for which we have compre. hensive assessments. About half of these workers received no measurable occupational dose. In that year the average worker measurably exposed to external radiation received an occupational dose equivalent of 0.2 rem to the whole body, based on the readin of individual dosimeters worn on the surface of the body. We estimate (auening a linear non threshold model) the increased risk of premature death due to radiation induced cancer for such a dose is approximately 2 to 5 in 100.000 and that 16. increased risk of serious hereditary effects 13 somewhat smaller. To put these estimated risks in perspective with other occupational hazards, the, are c(mparable to the observed risk of job-related accidental death in the safest h&r9ies, whole-sale andQctail tradt;s. for which the annual eccidental death rate averaged about 5 per 100.000 from 1980 to 1984. The U.S. average for all industries was 11 per 100,000 in 1984 and 1985. These recommendations are based on the anumption that risks ofinjury from exposure to radiation should be contMemd in relation to the overall benefit derived from the activities cmeg the exposure. This approach is simitar to that used by the Federal Radiation Council (FRC) in developing the 19M Federal guidance. The FRC said then. "Fundamentally, setting basic radiation protection star.dards involves passing judgraent on the extent of the possible health hazard so-iety is willing to accept in order to realize the known benefits of radiation." This leads to three basc principles that have governed radiation protection of' erkers in recent Acades in the United States and in most other countries. Although the precin formulation of these prisipN has evolved over the years, their intent has wntinued unchanged. The f;ra is that any activity involving occupational exposure should be determined to be useful enough to society to wrtant the exposure of workers: i.e, that a finding be made that the activity is "justified". This same principle apalies to virtually any human endeavor which involves some risk of mjury. The seccnd is that, for justified activities, exposure of the work force shoW be as low as reasonably achievable (commonly designated by the acron,pa ' ALARA"); this has most recently been characteriwi as "optimization" of :adiation protection by the International Commission, on Radiological Protection (ICRP). Finally, to provide an upper limit on risk 'a individual workers, "limitatic n" of the maximum allravec individual dose is required. This is required above ar,d beyond the "rotection provided by the first two principles because their g' primary objective is to minirnize :ae totei harm from occupational exposure in
2826 Fed:r:1 R: gist:r / Vol. 52 No.17 / Tuesdav, January 27, 1987 / Presidential Documents a. the entire work force: they do not limit the way that harm is distributed among r)s individual workers. ~ The principle : hat activities causing occupational exposure should produce a net benefit is important in radiation protection even though the judgment of net benefit la not easily me.de. The 1960 guidance says: "There should not be any man mada radiat!on exposure without the expectation of benefit resulting from such exposure. " And "It is basic that exposure to radiation should result from a real determination of its necessity." Advisory bodies other than the FRC have used language which has essentially the same meaning. In its most recent revision of international guidance (1977) the ICRP said ". . no practice shall be adopted unless its introduction produces a positive net benefit," and in sligntly different form the NCRP, in its most recent statement (1975) on this ma:ter, said " . all exposures should be kept to a practicable mmimum:,, this principle involves value judgments based upon perception of compensatory benefits commensurate with risks, preferably in the form of realistic numerical estimates of both benefits and risks from activities inves-ing radiation and alternative means to the same benefits." This principle is set forth in these recommendations in a simple form:"There should not be any occupational exposure of workers to ionizing radiation without the expectation of an overall benefit from the activity causing the exposure." An obvious difficulty in making this judgment is the difficulty of quantifying in comparable terms ccsts (including risks) and benefits. Given this situation, informed value judgments are necessary and are usually all that is possible. It is perhaos useful to observe, however, that throughout history individuals and societies have made rmk-benefit judgments, w:th their success usually depending upon the amount of accurate information available. Since more is known about radiation now than in previous decades, the prospect is (3 that these judgments can now be better made than before. 4"i The pra eding discussion has implicitly focused on major activ ties, i.e., those i instituting or continuing a general prcctice involving radiation exposure of workers. This principla also applies to detailed management of facilities and direct supervision of workers. Decisions on whether or not particular tasks should be carried out (such as inspecting control systems or acquiring specific experin ental data) require judgments which can, in the aggregate, be as significant for radiation protection as those justifying the basic activities these tasks support. The principle of reduction of exposure to levels that are "as low as reasonably achievable" (ALARA) is typically implemented in two different ways. First, it is applied to the engineering design of facilities so as to reduce, prost ectively, the anticipated exposure of workers. Second, it is applied to actual operations: that is, work practices are designed and carried out to reduce the exposure of workers. Both of these applications are encompassed by these recommenda-tions.* The principle applies both to collective exposures of the work force and to annual and cumulative inuividual exposures. Its application may therefore regt. ire complex judgments, particularly when tradeoffs between collective and individual doses are involved. Effective implementation of the ALARA principle involves most of the many facets of ali effective radiation protection program: education of workers concerning the health risks of expo ute to radiation; training in regulatory requirements and procedures to control exposure; monitoring, assessment and reporting of exposure levels and doses: and management and supervision of radiation protection activities, including the choice and implementation of radiation control measures. A comprehensive radietion proie: tion program will also include, as appropriate. j (V)
- The recomendation that cederal agencies, through their reguhtions. operational procedures and other appropriate rroans. maintain deses \\lARA is not intended tc' express, and therefore should not be interpreted as expressmg. a view whether the AtARA concept should constitute a duty of care m wrt htigation. Implementaton of the AIARA concept requires a complex.
l subjective balancing of scientific. economic and social factors generaHy resultmg in the attam-l ment of average dose lesel, significantly below the maxi; nom permitted by this guidance 1
i Fr.letal Regist:r / Vol. 52, No.17-/ Tuesday, Janc.ary 27, 1987 / Preiidential Documents 2827 { a prnperly trained and qualified rad:ation protection personnel; adequate des!sned, operated, and maintained facilities and equipment; and quality assurance and audit p;ocedures. Another irtportant aspect of such programs is maintenance of records of cumulative exposures of workers and implementa-tion of appropriate measures to assure that lifetime expostwe of workers repeatedly exposed near the limits is minimized. The types of work and activity which involve worker exposure to radiation vary greatly and are administered by many different Federal and State agencies under a wide variety of legislative authcrities. In view of this complexity, Federal radiation protection guidance can address only the broad preregt.isites of an effective ALARA program, and regulatory authorities must ensure that more detailed requirements are identified and carried out. In doing inis, such authorities may find it useful to establish or encourage the use of 1) administrative control levels specifying, for specific categories of workers or work situations, dose levels below the limiting nu.aerical values recommend-ed in this guidance: 2) reference levels to indicate the need for such actions as recording, investigation, and intervention; and 3) local goals for limiting individual and collective occupational exposures. Where the enforcement of a general ALARA requirement is not practical under un agency's statutory authority, it is sufficient that an agency endorse and encourage ALARA, and establish such regulations which result from ALARA findings as may be aseful and appropriate to meet the objectives of this guidance, The numerical radiation protection guidance which has been in effect since 1960 for limiting the maximum allowed dose to an individual worker is based on the concept of limiting the dose to the most critically exposed part of the body. This approach was appropriate, given the limitations of scientific information available at that time, and resulted in a set of five independent numerical guides for maximum exposure of a) the whole body, head a active blood forming organs, gonads, and lens of eye: b) thyroid and skin of the whole body: c) hands and forearms, feet and ankles: d) bone, and e) other organs. A conseauence of this approach when several different parts of the body are exposed simultaneously is that only the part that receives the highest dose relative to its respective guide is decisive for limiting the dose. Current knowledge permits a more comprehensive approach that takes into account the separate contributions to the total risk from each exposed part of the body. These recommendations incorporate the dose weighGg system introduced for this purpose by the ICRP in 1977. That system assigns weighting , actors to the various parts of the body for the risks of lethal cancer ano serious prompt genetic effects (those in the first two generations) these factors are chosen so that the sum of weighted dose equivalents represents a risk the same as that from a numerically equal dose equivalent to the whole body. The ICRP recommends that N effective (i.e. weighted) dose equivalent incurred in any year be limited to 5 rems. Based on the public response to the similar proposal published by EPA in 1981 and Federal experience with comparable exposure limits, the Federal agencies concur. These recommenda-tions therefore replace the 1960 whole body numerical guides of 3 rems per l quarter and ;(N-18) rems cumulative dose equivalent (where N is the age of the worker) and associated critical organ guides with a limiting value of 5 i rems effective dose equivalent incurred in any year, Supplementary limiting values are also recommended to provide protection against those health t effects for which an effective threshold is believed to exist. In recommending a limiting value of S rems in any single year, EPA brs had to br. lance a number of considerations. Public comments confirmed that, for some beneficial activities, occasional doses aproaching this value are not reasonably avoidable. On the other hand, continued annual exposure near this level over substantial portions of a working lifetime would, we believe, lead to unwarranted risks. For this reason such continued annual exposures should be avoided, and these recommendations provide such guid-ance. As noted earlier, these recommendations also continue a system of protection which combines limiting values for maximum dose with a require-
2828 Federal Register / Vol. 52, No.17 / Tuesday, January 27, 1987 / Presidential Documents 7 1 ment for active appl! cation of measures to minimize doses-the ALARA Q requirement. This has resulted in steadily decreasing average annual doses to workers (most recently to about one-fiftieth of the recommended limiting value), and, to date, only a few hundred out of millions of workers have received planned cumulative doses that are a substantial f setion of the maximum previously permitted cumulative dose over an occupationallifetime. EPA anticipates that the continued application of the ALARA requirement, combined with new guidance on avoidance of large cumulative doses, will result in maintaining risks to all workers at low levels. EPA will continue to review worker doses with a view to initiating recommendations for any further modifications of the dose limitation system that are warranted by future trends in worker exposure. Certain radionuclides, if inhaled or ingested, may remain in and continue to irradiate the body for many years. These recommendations provide that radionuclides should be contained so as to minimize intake, to the extent reasonably achievable. When avoidance of situathns that may result in such intake is not practical, the recommendations distinguish between pre-expo-sure and post exposure situations. With respect to the former, Federal agen-cies should base control of prospective internal exposure to radionuclides (e.g. facility design, monitoring, training, and operating procedures) upon the entire future dose that may result from any intake [the committed dose), not just upon the dose accrued in the year of intake. This is to assure that, prior to exposure to such materials, proper account is taken of the risk due to doses in future years. With respect to post exposure situations, most significant internal exposure to radionuclides occurs as the result of inadvertent intakes. In the case of some long-lived radionuclides, it may also be difficult to measure accurately the (Vl small quantities corresponding to the recommended numerical guidance for control of committed doses, in such cases, when workers are inadvertently exposed or it is not otherwise possible to avoid intakes in excess of these recommendations for control of committed dose, it will be necessary to take appropriate corrective action to assure control has been reestablished and to properly manage future exposure of the worker. In regard to the latter requirement, provbion should be made to continue to monitor the annual dose received from radionuclides in the body as long as they remain in sufficient amount to deliver doses significant compared to the limiting values for annual dose. These recommendations extend those of the ICRP, because it is appro-priate to maintain active management of workers who exceed the guidance for committed dose in order that individual differences in retention of such materials in the body be monitored, and to assure, whenever possible, con-formance to the limiting values for annual dose. These recommendations also incorporate guidance for limiting exposure of the unborn as a result of occupational exposure of female workers. It has long J. been suspected that the embryo and fetue are more sensitive to a variety of effects of mdiation than are adults. Although our knowledge remains incom-plete, it h3s now become clear that the unborn are especially subject to the ) risk of mental retardation from exposure to radiation at a relatively early phase of fetal development. Available scientific evidence appears to indicate that this sensitivity is greatest during the period near the end of the first trimester and the beginning of the second trimester of pregnancy, that is, the period from 8 weeks to about 15 weeks after conception. Accordingly, when a woman has declared her pregnancy, this guidance recommends not only that the total exposure of the unborn be more limited than that of adult workers, but that the monthly rate of exposure be further limited in order to provide g additional protection. Due to the incomplete state of knowledge of the transfer Q of radionuclides from the mother to the unborn (and the resulting uncertainty in dose to the unborn),in those few work situations where intake of radionu-clides could norn. ally be possible it may also be necessary to institute measures to avoid such intakes by pregnant women in order to sa:isfy these recommendations. {
Federal Register / Vol. 52, No.17 / Tuesday, January 27, 1987 / Presidential Documents 2829 l T'.a health protection objectives of this guidance for the unborn should be achieved in accordance with the provisions of Tale Vil of the Civil Rights Acth of 1964, as amended, with respect to discrimirstion in employment practicea.* The guidance applies only to situations in which the worker has voluntarily made her pregnancy known to her employer. Protection of the unborn may be 4 achieved through such measures as temporary job rotation, worker self-selection, or use of protective equipment. The guidance recognizes that protec-tion of the unborn is a joint responsibility of the employer and worker. Workers should be informed of the risks involved and encouraged to voluntar-ily make pregnancies known as early as possible so that any temporary arrangements necessary to modify exposures can be made. Conversely, em-ployers should rnake such arrangements in a manner that minimizes the impact on the worker. The recommended numerical guidance for limiting dose to workers applies to the sum of dose froni external and internal sources of radiation. This proce-dure is recommended so as to provide a single limit on the total risk from radiation exposure. Therefore, in those cases where both kinds of radiation sources are present, decisions about the control of dose from internal sources should not be made without equal consideration of their implication for dose from external sources. The guidance emphasizes the importance of recordkeeping for annual, com-mitted, and cumulative (lifetime) doses. Such recordkeeping should be de-signed to avoid burdensome requirements for cases in which doses are insignificant. Currently, regulatory records are not generally required for doses small compared to regulatory limits for annual external and internal doses. lInder this guidance such regulatory practices would continue to be appropri-ate if due consideration is given to the implications of summing internal and external doses and to recordkeeping needs for assessing cumulative doses. Tc the extent reasonable such records sho :ld be established on the basis o individual dosimetry rather than on monitoring of exposure conditions. In summary, many of the important changes from the 1960 guidance are structural. These inch de introduction of the concept of risk based weighting of doses to different parts of the body and the use of committed dose as the primary basis for control of internal exposure. The numerical values of the guidance for maximum radiation doses are also modified.These changes bring this guidance into general conformance with international recommendations and practice, in addition, guidance is pros ided for protection of the unborn. and increased emphasis is placed on eliminating unjustified exposure and on keeping justified exposure as low as reasonably achievable, both long-stand-ing tenets of radiation protection. The guidance emphasizes the importance of instruction of workers and their supervisors, monitoring and recording of l doses to workers, and the use of administrative control and reference levels j for carrying out AI. ARA programs. These recommendations apply to workers exposed to other than normal background radiation on tl e job. It is sometimes hard to identify such workers j because everyone is exposed to natural sources of radiation and many t occupational exposures are small. Workers or workplaces subject to this guidance will be identified by the responsible implementing agencies. Agen-cies will have to use care in determining when exposure of workers does not I need to be regulated. In making such determinations agencies should consider
- 1he Ciul Rights Act of 19r>4. as amended. presides that "It shall be an unlawfu' employment l
practice for an employer (1) to fail or refuse to hire or lo discharge any individual, or otherwise to l discriminate egainst any individual with respect to his compensation. terms, conditior.s. o-( priuleges of employment. because of such individuars.. se s.. or (2) to hmit. segrega te. < l classify his employers or applicants for employment in any way which would deprae or tend to deprne any indindual of employment opportumties or otherwise adsersely affect his status as an employee, because of such individual s. sex. ' 142 U.S.C. 2000e-2(a)] The Pregnancy thscrimination Act of 19'8 defines "because nf ser to include because of or on the basis of pregnancy. childbirth. or related medical conduions [42 ILS C 200*(kil. )
2830-Fe feral Register / Vol. 52, No.17 / Tuesday, January 27, 1987 / Presidential Documents rm both the collective dose which is likely to be avoided through regulation and (j the maximum individual doses possible. Implementation of these recommendations will require changes that can reasonably be achieved only over a period of time it is expected that Federal agencies willidentify any problem areas and provide adequate flexibility and the necessary transition periods to avoid undue impacts, while at the same time assuring reasonably prompt implementation of this new guidance. Upon implementing these recommendations, occupational exposure should be reduced. It is not possible to quantify the overall exposure reduction that will be realized because it cannot be predicted how efficiently these recommenda-tions will be implemented or how much of existing exposua unnecessary. These recommendations reduce the maximum whole body dose that workers may receive in any one year by more than half (i.e., from 3 rems per quarter to I 5 rems per year), require that necessary exposure to internal radioactivity be controlled on the basis of committed dose, require that internal and external doses be considered together rather than separately, and provide increased protection of the unborn. We also expect the strengthened and more explicit recommendations for maintaining occupational exposure "as low as reason-ably achievable" will improve the radiation protection of workers. Finally, these recommendations would facilitate the practice of radiation protection by introducing a self consistent system of limits in accordance with that in practice internationally. Recommendations The following recommendations are made for the guidance of Federal agen-cies in their conduct of programs for the protection of workers from ionizing p radiation. "/
- 1. There should not be any occupational evposure of workers to ionizing radiation without the expectation of an overall benefit from the activity causing the exposure. Such activities may be allowed pravided exposure of workers is limited in accordarce with these recommendations.
- 2. No exposure is acceptable without regard to the reason for permitting it, and it should be general practice to maintain doses from radiation to levels below the limiting values specified in these recommendations. Therefore, it is fundamental to radiation protection that a sustained effort be made to ensure tilat collective doses, as well as annual, committed, and cumulative lifetime individual doses, are maintained as low as reasonably achievable (AIARA),
economic and social factors being taken into account.
- 3. In addition to the above recommendations, radiation doses received as a result of occupational exposure should not exceed the limiting vahes for assessed dose to individual workers specified below. These are given sepa-rately for protection against different types of effects on health and apply to the sum of doses from external and internal sources of radiation. For cancer and genetic effects, the limiting value is specified in terms of a derived 3
quantity called the effective dose equivalent. For other health effects, the limiting values are specified in terms of the dose equivalent ' to specific organs or tissues. ' "Dose equisalent"is the product of the absorbed dose. a quality factor which saries with the energy and type of radiation, and other modifying factors as defmed by the International Commission on Radiation Umts and Measurernents. v
Federal Register / Vol. 52, No.17 / Tuesday, January 27, 1987 / Presidential Documents 2831 Cancer and Genetic Effects. The effective dose equivalent, He, received in any year by an adult worker should not exceed 5 rems (0.05 sievert).8 The effective dose equivalent is defined as: "T "T ' 11 E T where w is a weighting factor and Hr is the annual dose equivalent averaged r over organ or tissue T. Values of w, and their corresponding organs and k tissues are: Gonads 0.25 Brea sts.. 0.15 Red bone marrow. 0.12 0.12 g Lungs.. 0.03 / Thy roid...- Bone surfaces._ 0.03 Remainder 8 0.30 For the case of uniform irradiation of the whole body, where Hr may be assumed the same for each organ or tissue, the effective dose equivalent is equal to the dose equivalent to the whole body. Other Health Effects. In addition to the limitation on effective dose equivalent, the dose equivalent, Hr, received in any year by an adult worker should not exceed 15 rems (0.15 sievert) to the lens n' ' sye, and 50 rems (0.5 sievert) to any other organ, tissue (including ..J, or extremity 4 of the body. Additional limiting values which apply to the control of dose from internal exposure to radionuclides in the workplace are specified in Recommendation
- 4. Continued exposure of a worker at or near the limiting values for dos;,
received in any year over substantial portions of a working lifetime should be avoided. This should normally be accomplished through application of appro-priate radiation protection practices established under Recommendation 2.
- 4. As the primary means for controlling internal exposure to radionuclides, agencies should require that radioactive materials be contained, to the extent reasonably achievable, so as to minimize intake. In controlling internal expo-sure consideration should also be given to concomitant external exposure.
The control of necessary exposure of adult workers to radioactive materials in the workplace should be designed, operated, and monitored with sufficient frequency to ensure that, ?s the result of intake of radionuclides in a year, the following limiting vahts A control of the workplace are satisfied: (a) the anticipated magnitude of the ccmmitted effective dose equivalent from such intake plus any annual effective dose equivalent from external exposure will not exceed 5 rems (0.05 sievert), and (b) the anticipated maritude of the committed dose equivalent to any organ or tissue from such intake plus any annual dose equivalent from external exposure will not exceed 50 rems (0.5 sievert). The commit'.ed effective dose equivalent from internal sources of radiation, Hr.so,is defined as: "E,50 " T "T,50 ' T 8 The unit of dose equivalent in the system of special quantities for ionizing radiation currently in use in the United States is the "rem." In the recently. adopted international system (SI) the un of dose equivalent is the "sies ert". One sievert = 100 rems. 8 "Remainder" means the five other organs (such as liver, kidneys. spleen, brain. thymus, adrenals. pancreas. stomach. small intestine, upper large intestine, and lower large intestine, but excluding skin lens of the eye. and extremities) with the highest doses. The weighting factor for each such o:gan is 0.06.
- "Extremity" means the forearms and hands or the lower legs and feet.
2832 Federal Register / Vol. 52, No.17 / Tuesday, January 27, 1987 / Presidential Documents where wr is defined as in Recommendation 3 and the committed dose ) equivalent, Hr.so, is the sum of all dose equivalents to organ or tissue T that may accumulate over an individual's anticipated remaining lifetime (taken as 50 years) from radionuclides that are retained in the body. These conditions on committed doses should provide the primary basis for the control of internal exposure to radioactive materials.8 in circumstances where assessment of actual intake for an individual worker shows the above conditions for control of intake have not been met, agencies should require that appropriate corrective action be taken to assure control has been reestablished and that future exposure of the worker is appropriately managed. Provision should be made to assess annual dose j equivalents due to radionuclides retained in the body from such intake for as long as they are significant for ensuring conformance with the limiting values { specified in Recommendation 3. i.
- 5. Occupational dose equivalents to individuals under the age of eighteen should be limited to one-tenth of the values specified in Recommendations 3 and 4 for adult workers.
- 6. Exposure of an unborn child should be less than that of adult workers.
Workers should be informed of currrent knowledge of risks to the unborn
- from radiation and of the responsibility of both employers and workers to minimize exposure of the unborn. The dose equivalent to an unborn as a result of occupational exposure of a woman who has declared that she is pregnant should be maintained as low as reasonably achievable, and in any case should not exceed 0.5 rem (0.005 sievert) during the entire gestation period.
Efforts should be made to avoid subatantial variation above the uniform monthly exposure rate that would satisfy this limiting value. The limiting value for the unborn does not create a basis for discrimination, and should be achieved in conformance with the provisions of Title VII of the Civil Rights Act (",) of 19M, as amended, regarding discrimination in employment practices, in-cluding hiring, discharp, compensation, and terms, conditions, or privileges of employment.
- 7. Individuals occupationally exposed to radiation and managers of activities involving radiation should be instructed on the basic risks to health from ionizing radiation and on basic radiation protection principles. This should, as a minimum, include instruction on the somatic (including in utero) and genetic effects of ionizing radiation, the recommendations set forth in Federal radi.
ation protection guidance for occupational exposure and applicable reguia-tions and operating procedures which implement this guidance, the general levels of risk and appropriate radiation protection practices for their work situations, and the responsibilities of individual workers to avoid and mini-mize exposure. The degree and type of instruction that is appropriate will depend on the potential radiation exposures involved. l
- 8. Appropriate monitoring of workers and the work place should be performed and records kept to ensure conformance with these recommendations. The types and accuracy of monitoring methods and procedures utilized should be periodically reviewed to assure that appropriate techniques are being compe-tently applied.
Mairtenance of a cumulative record of lifetime occupational doses for each l worker is encouraged. For doses due to intake of radioactive materials, the l committed effective dose equivalent and the quantity of each radionuclide in i the body should be assessed and recorded, to the extent practicable. A summary of annual, cumulative, and committed effective dose equivalents should be provided each worker on no less than an annual basis; more h
- When these conditions on intake of radioactise matenals have been satisfied. it is not V
necessary to assess contnbutions from such intakes to annual doses in future Sears. and, as an operational procedure, such doses rr.ay be assigned to the year of intake for the purpose of assessing compliance with Recommendation 3.
- The term "unborn" is defined to encompass the period commencing with conception and ending with birth
+ { Federal Register / Vol. M, No.17 / Tue; day, January 27, 1987 / Presidential Documents 2833 detailed information concerning his or her exposure should be made available upon the worker's request. g
- 9. Radiation exposure control measures should be designed, selected, utilized, and maintained to ensure that anticipated and actual doses meet the objec-tives of this guidance. Establishment of administrative control levels' below the limiting values for control may be useful and appropriate for achieving this I
objective. Reference icvels* may also be useful to determine the need to take such actions as recording, investigation, and intervention. Since such admin-istrative control and reference levels will often involve ALARA consider-ations, they may be developed for specific categories of workers or work situations. Agencies should encourage the estaolishment of measures by which management can assess the effectiveness of ALARA efforts, including, where appropria e, local goals for limiting individual and collective occupa-tional doses. Suparvision should be provided on a part time, full-time, or task-by-task basis as necessary to maintain effective control over the exposure of workers.
- 10. The numerical values recommended herein should not be deliberately exceeded except during emergencies, or under unusual circumstances for which the Federal agency having jurisdiction has carefully considc;ed the reasons for doing so in light of these recommendations. If I ederal agencies authorize dose equivalents greater than these values for unusual circum-stances, they should make any generic procedures specifying conditions under which such exposures may occur publicly available or make specific instances in which such authorization has been given a matter of public record.
The following notes are provided to clarify application of the above recom-mendations:
- 1. Occupational exposure of workers does not include that due to normal background radiation and exposure es a patient of practitioners of the healin arts.
- 2. The existing Federal guidance (34 FR 576 and 36 FR 12921) for limiting exposure of underground miners to radon decay products applies independ-ently of, and is not changed by, these recommendations.
- 3. The values specified by the international Commission on Radiological Protection (ICRp) for quality factors and dosimetric conventions for the various types of radiation, the modela for reference persons, and the results of their dosimetric methods and metabolic models may be used for determining conformance to these recommendations.
- 4. "Annual Limits on intake" (Alls) and/or "Derived Air Concentrations" (DACs) may be used to limit radiation exposure from intake of or immersion in radionuclides. The ALI or DAC for a single radionuclide is the maximum intake in a year or average air concentration for a working year, respectively, for a reference person that, in the absence of any external dose, satisfies the conditions on committed eff=ctive dose equivalent and committed dose equiv-l alent of Recommendation 4. ALis and DACs may be derived for different chemical or physical forms of radioactive materials.
- 5. The numerical values provided by these recommendations do not apply to workers responsible for the management of or response to emergencies.
These recommendations would replace those portions of current Federal Radiation Protection Guidance (25 FR 4402) that apply to the protection of workers from ionizing radiation. It is expected that individual Federal agen-cies, on the basis of their knowledge of specific worker exposure situations. Administratise control lesels are requirements determined by a competent authority or il man 4gement of an mstitution or faaht). They are not primary hmits. and may therefore L euceded upon approsal of competent authority or management, as situations dictate.
- Reference lesels are not hmits. and may be espressed m terms of any useful parameter. They are used to determine a course of actmn such as recordmg. nsestigation. or intersentmn. when the s alue of a pa ameter esceeds. or is projected to cuecd. the reference lesel
2834 Federal Register / Vol. 52, No.17 / Tuesday, January 27, 1987 / Presidential Documents will use this new guidance as the basis upon which to revise or develop f ~s ("'). detailed standards and regulations to the extent that they have regulatory or administrative jurisdiction. The Environmental Protection Agency will keep informed of Federal agency actions to implement this guidance, and willissue any necessary clarifications and interpretations required to reflect new infor-mation, so as to promote the coordination necessary to achieve an effective Federal program of worker protection. If you approve the foregoing recommendations for the guidance of Federal j' agencies in the conduct of their radiation prctection activities, I further recommend that this memorandum be published in the Federal Register. i Lee M. Thomas, Administrator. Environmental Protection Agency. \\ (FK Doc. 87-1716 filed 1-22-87; 9 44 at. } ikiling code 65m50-M b( ) i O
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-e9 3 %,4 TT U PRACTICAL POINTS ABOUT ANNUAL AND COMMITTED DOSE AT COMMERCIAL NUCLEAR FUEL PLANTS 3 COMMON POINTS UNDER EITHER APPROACH o Urinalysis would be needed to control intake of soluble uranium to 2.7 mg/ week, o For a worker consistently exposed at the limit under either system, the lifetime dose would be the same (a hypothetical example). o ALARA efforts / requirements would govern the doses of most workers and keep them in the aggregate far below either limit. r~g O O
6" I COMMITTED DOSE CONTROL -fv o Compl'iance demonstrated by determining and summing a large number of small intakes (i.e., daily). Intake determined by air sampling or fecal sampling. Representativeness of air sampling is an important issue to management, regulatory agencies and litigants, o Practical application requires use of Reference Man values for lung clearance, o Representativeness' issue kills use of particle-size adjustment of DAC. o Over exposures (>2000 DAC-hr/yr) restrict worker for remainder of calendar year and subsequently have no effect (i.e., are O written-off). o Practical importance of on-site lung counter diminishes. O
I ANNUAL DOSE CONTROL (_)\\ o Compliance demonstrated by determining time-weighted lung contents. Could be done with monthly and quarterly lung' counts (resulting in about'4 times as many). Lung count limit for low-enrichment uranium (i.e., 3%) doesn't change much from'ICRP 2 value. Lung counting would become more accurate as lung contents approach limit. o Lung counting is_a direct measurement. No question of representativeness. Lung counting measurements account for different individual clearance times, particle size and solubility. () Performance criteria for lung counting accreditation almost available. (HPS/ ANSI performance standard on Bioassay.) o Lung counting accounts for previous intakes, does not "write off" prior dose. o Air sampling would still be necessary and useful to control factory environment on a day-to-day basis. Action guides would be referenced to DAC. Lung counting not sensitive enough to determine intakes at levels of operational interest, say 40 DAC-hr. O
~ O O O. 4 Derived Limit Corresponding to 3 Rem Effective Dose Limit i Annual Annual Organ Derived Effective Organ Contents Lung Count Dose Weighting Dose SEE Limit Specific Limit Factor Limit Limit (activity) (ug U-235) Enric ment i
O O O Calculational Details 3 rems (eff) 1 rem (lung) 25 rems (lung) year 0.12 rems (eff) year 25 rems trans 1 year 510 trans y year 1.55 x 10 -9 3.15 x 10 7 rems s s 510 trans 60s 1 uCi X X = 0.0138 uCi s m 2.22 x 10 6 trans/m 0.0138 uCi ug U 11,500 ug U y = 1.2 x 10 -6 uCi x 3% (enrichment) 345 ug U-235
4 I I 4M ll l l I I l l l I I I """" _i l [ N ~ -l N -l \\ 325 ug \\ 300 \\ l h i. l mg I 200 I I _l _1 100 1 1 I I I I I I I I I 0 10 20 30 40 60 60 70 80 90 100 3I w/o U-235 Fpro D4 Equilibrium Man of U-235 in the Lung Equivalent to 1 Maximum Perminible Lung Burden from WASH - 1251 O
l L COST ESTIMATES Jack Faucette Associates Study for NRC. 1982 $28 million to the uranium fuel fab industry most related to controlling on the basis of committed dose. 1985 NESP Study $0.25 Million per uranium facility to detect and control on the basis of lung counting (annual dose control). 1986 Westinghouse Water Reactor Division formal comments on the proposed 10 CFR 20 changes. $15 Million for Westinghouse facilities based on committed dose control. They suggest "the assignment of a committed effective dose in the year of intake should be modified to f-require assignment of the estimated dose received in the year of record". 1988 $6 to $10 Million for GE facilities to comply with committed dose control. I r l ~
I' e (') OUTLINE OF ORAL STATEMENT MADE TO ACRS SUBCOMMITTEE \\' ON OCCUPATIONAL AND ENVIRONMENTAL PROTECTION SYSTEMS MEETING MAY 31, 1988 GE Nuclear Fuel & Components Mfg. would speak in favor of retaining the proposed paragraph 20.205 - provisions for internal exposure involving radionuclides with very long effective half-lives. The provisions are in line with national, international, Presidential guidance, and professional society recommendations. The provisions are consistent with the approach taken by the DOE. These provisions promote the use of lung counting in the commercial uranium fuel fabrication industry. Lung counting has some features which technically and practically GE judges to be superior to other internal exposure assessment techniques. The use of lung counting to assess doses to personnel avoids /~') extensive, assumed conservatism inherent in dose assignment from \\' air sampling, with no reduction in overall protection to personnel. Deletion of the proposed paragraph 20.205 will require doses be determined by air sampling. The proximity of present plant conditions to the proposed DAC will require large costs to the industry (GE estimates the cost of compliance for itself alone to be in the range of 6 to 10MS. Costs for other U.S. uranium fuel f abricators are likely to be similar or larger depending on their plant conditions.) Paul S. Stansbury GE Nuclear Fuel & Components Mfg. Wilmington, N.C. () l
INTERNATIONAL AND NATIONAL SCIENTIFIC GUIDANCE A /^) \\' (175) Use can be made of derived limits or authorized limits in the application of individual monitoring programs. Such limits are essential in the monitoring of operations where, in general, only part of the dose-equivalent limit or secondary limit can be committed to the operation. (176) Only in a few circumstances can the results of programs of monitoring of the workplace be used to estimate the dose equivalents or intakes of individual workers. ICRP 26. It is stressed that the total dose equivalent which an individual has actually received and that to which he might be committed as a result of past exposure to radioactive materials is the primary factor determining his radiation status. ICRP 30, p4. The NCRP, therefore, favors the adoption of a new system of radiation protection such as that embodied in the use of the committed effective dose equivalent concept, but with stringent reservations as to the appropriate applications of that system. Its use should be limited to prospective protection planning, as reflected in derived standards for control of the workplace environment, and to such administrative operations as may be () required by regulatory bodies to evaluate compliance by the employer with regulatory standards. A committed effective dose equivalent system should specifically not be used as a measure of an individual worker's exposure status. Recognition of this restriction is essential if the system is not to be abused. A statement of "permissible body burden" or "permissible organ burden" (perhaps better expressed as "derived" body burden or "derived" organ burden) remains the most practical guide to the actual internal exposure status of the individual. It is the total quantity of radionuclide deposited that determines dose equivalent to the tissue (which is the focus of the primary standard); it is this quantity that can be and is most often measured or estimated in practical health physics evaluations, frequently by regulatory requirements for routine bioassay. It is this quantity that most directly correlates with possible health consequences to the individual. The establishment of organ radionuclide burdens equivalent to the dose limit set by the primary standard is a necessary component of a system for control of internal emitters, if that system is to serve as a useful guide in the evaluation of individual exposures. NCRP 84, p. 38 & 39. (v~\\
O FEDERAL RADIATION PROTECTION GUIDANCE FOR OCCUPATIONAL EXPOSURE, JANUARY 27, 1987 "The limiting value for assessed dose to individual workers" should be based on the annual effective dose equi'/alent. "Limiting valuea for control of the workplace" should be based on committed dose. O ~ I i O l
1 t. m e O U.S. DEPT. OF ENERGY ORDER DOE 5480.11 DRAFT OF 8/3/87 The annual effective dose equivalent from both internal and external sources (retrospective) received in any year by an occupational worker shall not exceed 5 rem (0.05 sievert). p. 7 DOE COMMEPTS ON JAN. 9 DRAFT OF 10 CPR 19, ET AL The DOE conti'iues to believe the retrospective dose limitation sy.. tem should be based on a consistent application o. the annual dose equivalent rather than on committed dose equivalent. The NRC proposes to provide (]) an exemption from its basic committed dose limitation system for five select radionuclides. This introduces a dual and inconsistent system that has no apparent technical basis. Further, by introducing an exemption, it would appear that the NRC, itself, recognizes that a retrospective dose limitation system based on committed dose is not technically valid.
9 O HEALTH PHYSICS SOCIETY Study Group of Low Enrichment Uranium Fuel Fabricators (under State and Federal Legislation Committee) worked with NRC Staff to develop the proposed paragraph 20.205 provisions. (1982-83) Ad Hoc Committee recommended to the Board of Directors: 1. Design and planned be based on committed dose. 2. When intakes of persistent nuclides occurred which exceeded committed dose, control of doses to workers should be based on annual dose. In this case both annual and residual committed dose should be reported to the worker. (9184) The Health Physics Society Board of Directors adopted the (]) committee recommendation. (1984) The Health Physics Society by referendum confirmed the Board position. (1985) l l l l l ()
o o O i X 99.9 vi i 99.9 n/ 8 / O 99 z/ 0 W f 95 / 3, 90 '7 I by 2 y 75 50 h'- / r / D p' / u-25 - 'p' / O o. / 10 f u.o 5 / o o o o 2 / 1 / l- / 6 / i ) o 0.1 / \\ 1 / i A i Iiitil i i i l i iii i i i l iiill i i i i i i ill E 0.01 0.001 0.005 0.01 0.05 0.1 0.5 1.0 5 10 ANNUAL RADIATION DOSE (TOTAL BODY rem) l 1
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-() PART 20 REVISI0N o PURPOSES OF REVISION:
- 1. Update scientific basis for dose and concentration limits.
- 2. Provide explict limits for protection of the public.
- 3. Provide explict limits for protection of the embryo / fetus.
- 4. Adopt ICRP-26 risk-based dose-limitation system.
- 5. Implement revised Federal guidance on occupational radiation exposure.
- 6. Provide better organization of 10 CFR Part 20.
7-V l l l i I lu O L
l. .9 PART 20' R E V I S I 0 N 1 o DEFICIENCIES OF PRESENT 10 CFR PART 20:
- 1. Scientific information underlying concentration limits is outdated (proposed rule 1955, final 1959).
- 2. Protection of public primarily based on concentration limits, no explicit annual dose limit.
- 3. No explicit limit for protection of the embryo / fetus.
- 4. Does not employ ICRP-26 system and newer concepts such as the "effective dose equivalent."
- 5. Does not reflect January 1987 revised Federal guidance.
O
- 6. Has been amended over 90 times in piecemeal fashion without a major overall revision.
O 2
U + O). ( PART 20 REVISI0N o BENEFITS OF PART 20 REVISION:
- 1. Conformance to Federal guidance provides compatability with standards of other U.S. agencies and with most of NCRP's recent recommendations.
- 2. Adoption of ICRP-26 Dose Limitation System provides high degree of compatability with national standards of other countries and international standards (CEC, OECD/NEA, and IAEA Basic Safety Standards).
- 3. Risk-based approach should provide better understanding of basic protection goals.
O
- 4. use of updated metabolic and dosimetric parameters (ICRP-30, ICRP-48) provides better scientific basis for derived (concentrationandintake) limits.
- 5. Provides consistency in treatment of internal and external doses.
l l { O 3
l T (\\~s/ PART 20 R E V I S I 0 N o COSTS ASSOCIATED WITH PART 20 REVISION:
- 1. New quantities (e.g. effective dose equivalent) and system of dose limitation introduce greater complexity into radiation protection practice.
- 2. Changes in fundamental cpproach and new quantities will require revision of recordkeeping and reports.
3.-Reduction in air concentration limits for natural uranium and uranium-238 may necessitate expensive modification of fuel fabrication facilities and procedures.
- 4. Requirement to notify workers annually of their dose has significant cost.
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i O PART 20 'R E Y I S 1 0 N o GENERAL CHANGES FROM PROPOSED RULE: General
- 1. Portions'have been entirely drafted to improve readabili:y.
- 2. Non-regulatory tutorial material has been greatly reduced.
- 3. Definitions have been revised and reorganized.
O O 5 - ^n,
p. ~ - - .. nU PART 20 REVISION o CHANGES TO UPDATE PRESENT AND PROPOSED RULES:
- 1. Incorporated final provisions of the 1987 Federal guidance on Occupational Radiation Exposure.
- 2. Revised dose limit for members of the public to conform to lctest ICRP position.
- 3. Incorporated final dosimetry processor accreditation rule.
- 4. Incorporated revised (ICRP-48) actinide GI tract upteke parameters in DACs and ALIs.
- 5. "Form of Record" section revised to permit the use of "electronic media" for record retention. (This is consis-()
tent with NRC agency policy). l l l l l CE) 6
PART 20 REV1SI0N o CHANGES MADE TO REDUCE IMPLEMENTATION COSTS:
- 1. Eliminated requirements for detailed documentation of ALARA actions.
-Counterproductive to encouraging ALARA levels. -Large associated recordkeeping cost.
- 2. Reduced requirement for surveying package upon receipt to:
-Packages labeled as containing radioactive materials under D0T regulations. -Packages showing visible damage or leaking.
- 3. Modified allowable record formats to include "electronic media" O
- 4. Eliminated termination reporto to NRC.
t i O 7
O PART 20 REVISION f 4 o CHANGES MADE TO PROPOSED RULE THAT INCREASE COSTS:
- 1. Deleted exception to use of "committed dose equivalent" for long-livedradionuclides(proposed 9 20.205).
-Exception would have allowed control of annual doses rather than committed dose equivalents. -Would have been inconsistent with NRC policy to provide for control of the workplace rather than the worker. 4 -Coupled with decrease in Derived Air = Concentration for uranium has large impact on fuel fabrication facilities. -Statement notes that Commission will consider requests for longer implementation times in order to make physical modifications to facilities.
- 2. Require annual reporting of individual doses by certain
(]) licensees: -Power reactors, -Radiopharmaceutical and large source processors, -Radiographers, -Low-level Radioactive Waste Disposal Sites, -High-level Radioactive Waste Repositories. -Independent Spent Fuel Storage Facilities, -Receivers of Radioactive Waste for processing.
- 3. Require annual reporting of dose to individual worker
-Present Part 19 (519.13) requires such data be provided at least annually "upon request." -Deletion of "upon request" necessary for conformance with revised Federal guidance on occupational exposure. -Change has significant cost, particularly to smaller licensees. -Some licensees already furnish annual dose reports to workers without prior requests. O 8
i i O P A R T 20 REVISION l o OTHER CHANGES FROM PROPOSED RULE:
- 1. Reinstated detailed protection req)uirements for large irradiators [present i 20.203(g ].
- 2. Changed record retention periods from 2 to 5 years or date of next inspection of radiation protection program.
-consistent with NRC standardization of record retention requirements. -Dose records and survey data must still be held for duration of license.
- 3. Eliminated cutoff on calculation of collective doses.
-Deferred until consideration of overall NRC "below regulatory concern" policy. (] -Part 20 does not require calculation of collective doses. -No cost impact from deletion.
- 4. Codified long-standing staff position that release of radio-active materials into sewer systems for sole use of licensees does not constitute "disposal into sanitary sewer systems."
- 5. Modified terminology for radiation warning signs:
-Restricted use of "DANGER" to radiation warning signs for i "High" and "Very-high" radiation areas; -Use of "CAUTION" restricted to "Radiation Areas" and "High Radiation areas." -Change elimirates use of "DANGER" for "radiation areas."
- 6. Reinstated incident notification criteria based on monetary loss and loss of use of the facility.
O 9 1
i PART 20 R E V I S I-0 N o AGREEMENT WITH ICRP RECOMMENDATIONS:
- 1. Adopts ICRP annual dose lirr'ts for workers (5 rem / year) and for the general public (0.1 rem / year).
- 2. Employs "effective dose equivalent" concept for internal doses.
- 3. Employs 50-year committed dose equivalent for internal doses.
- 4. Requires sumation of external and internal dose equivalent (if both are required to be measured).
- 5. Adopts ICRP-30 methodology and parameters for internal dose cL1culations (uses MIRD-type interorgan gamma dose contri-O butioas)-
- 6. Places primary reliance on annual dose limits and associated derived quantities (Annual Limit on Intake and Derived AirConcentrations).
- 7. Permits Planned Special Exposures (PSEs) outside of limits and provides lifetime dose limitation for PSEs, O
10
p...... J l O PART 20 REVISI0N o DEPARTURES FROM ICRP RECOMMENDATIONS:
- 1. Limit for protection of the embryo / fetus is based on lower NCRP recomendation (0.5 rem over pregnancy) rather than ICRP 1.5-rem value (Part 20 limit is consistent with Federalguidance).
- 2. The limit to members of the public (0.1 rem / year) is applied on an annual basis rather than a long-term average and only includes dose contributions from the licensed operation.
- 3. A 0.5-rem limit for unrestricted areas is avaiable only upon specific approval of the Comission.
- 4. Part 20 has a more restrictive annual dose limit on planned O
special exposures (5 rems / year) than ICRP-26 (10 rems / year).
- 5. Does not adopt "A" and "B" Working Conditions (monitoring required if expected doses would exceed 10% of external and internal dose limit rather than 30%).
l O l 11
l 1 u C) PART 20 REVISI0N o 1987 NCRP REC 0W4ENDATIONS NOT INCLUDED IN REVISION:
- 1. Cumulative lifetime dose limit of I rem x age in years (IN formula).
-no opportunity to gather public comments on this issue -could have potentially large impact on certain segments of nuclear industry -NRC planning study (FY 1990) of impact of such action.
- 2. Use of comitted effective dose equivalent for planning purposes and the use of annual doa,e for post-exposure control.
-(same rationale as deleting proposed for long-lived exemption).
- 3. A monthly 6se limit of 0.05 rem per month as well as a limit on the total gestation dose to the embryo / fetus.
O -Part 20 requirement that dose be evenly distributed over gestation period has same effect: 0.5 rem /9 months = 0.055.
- 4. Condition that "site operator" assess total exposure to the most exposed individual member of the public if estimated or measured exposures excead 25 percent of the 0.1-rem limit (25 millirems).
-creates difficulty for licensee to estimate doses to individual from sources outside of the licensee's control -dose estimates for members of the public are based primarily on calculated doses to "reference individuals" at locations of highest dose and not on assessing doses to actual persons.
- 5. The use of "reference levels" set up by the radiation user below l
the regulatory limits. -Discussed in proposed rule. -Reflects practice of industry, no codification required.
- 6. Concept of a "negligible level of risk" of 1 millirem per year as a floor to the practice of ALARA.
-Being considered with regard to NRC development of a policy on "Below Regulatory Concern" (BRC) levels. 1 12 1
.D) 'w/ PART 20 REV1SI0N o RECOMMENDATIONS OF THE U.K. NATIONAL RADIOLOGICAL PROTECTION BOARD (NRPB-GS9, November 1987) A. Occupational Exposure
- 1. The Board recommended that occupational workers' exposure should be controlled as not to exceed an average effective dose equivalent of 15 mSv [1.5 rems] per year.
- 2. The Board suggested that the present limit for the eye of 150 mSv [15 rem] be retained for skin and the lens.
B. Members of the Public 4 ()
- 1. The Board [and the ICRP] recommend that the principal dose limit for members of the public be 1 mSv [100 millirem]
per year and that this apply in all circumstances.
- 2. The Board recommended that doses to critical groups from effluent discharges from nuclear installations should be controlled as not to exceed an effective dose equivalent of 0.5 mSv [50 millirems] per year for a single site.
- 3. The total dose from pre-existing contamination in the environ-ment plus that from current discharges should be less than 1 mSv [100 millirems] per year.
- 4. The Board suggested that other than the skin and the lens of the eye, there is not need to limit individual organ doses l
to members of the public other than through the application of the effective dose equivalent. For skin and lens of the eye, a limit of 15 mSv [1.5 rems] would be adequate. O 13 L ,}}