ML20202F464
| ML20202F464 | |
| Person / Time | |
|---|---|
| Issue date: | 11/24/1975 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| References | |
| SECY-75-679, SECY-75-679-R, NUDOCS 9902040066 | |
| Download: ML20202F464 (35) | |
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~ b N t.% e _ Q PTFHCHAL USE ONLY SECY-75 679 November 24. 1975 umrto STATES NUCLEAR REGilLATORY COMMIS$10N
' POLICY SESSION ITEM lF*r The Commissioners
- From Robert B. Minogue, Director, Office of Standarda. Development Thrut Executive Director for Operations
- Subjects PROPOSED RULE MAKING PROCEEDING FOR COST-BENEFIT ANALYSES OF REDUCTIONS IN RADIATION EXPOSURE
! Purp*m s To obtain a Commission decision regarding (1) scope of the rule making proceeding and (2) EPA participation in a public meeting.
Cmt g ry:
This paper covers a maj1r policy question.
lI ue, 1.
Should this rule making proceeding be concerned with the dollar value of reduction,of radiation doses from LWR effluents only or should it also be concerned with the dollar value of reduction of doses from other NRC licensed activities?
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2.
Should NRC ask EPA to co-sponsor a public meeting in s
connection with the rule making proceeding?
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iDecision b
' Crit rin:
1.
Completion of'the rule making proceeding in an expeditious
- manner, 2.
Staff resources required to complete a rule making proceeding.
3.
Applicability of LWR dollar-per-man-rem and dollar-per-man-thyroid-rem values to cost-benefit evaluations of radiation doses resulting from other licensed activities.
4.-
Development of a consistent data base for use of both NRC and EPA.
Olt rnetives:
Issue 1, Scope:
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Alternative 1:
Institute n' rule making proceeding to establish the dollar value of reductions of radiation doses frc,a LWR effluents i
only.
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I Alternative 2:- Institute a rule making proceeding to establish the dollar value of reduction of radiation doses from effluents j
. of LWR's and other NRC licensed activities.
Issue 2 EPA Participation:
Alternative 1: Conduct-rule making proceeding without formal l
coordination with EPA.
6 Alternative 2: Ask EPA'to co-sponsor a public meeting to gather information.
7 niccu't. ion of i
Ierue-1. Scope:
The purpose of the proposed rule making proceeding is to assign a dollar value to a reduction of the population dose, expressed l
in man-rom. If the rule making proceeding is restricted to light i
water reactors, only the population dose for the whole body and 3
for the thyroid will be considered. However, it should be recog-nized that the dollar-per-man-rem and dollar-per-man-thyroid-rem values developed for LWR effluents may also be applicable to
- other exposure sources.
In some cases, where radiation exposure conditions are similar, this broader application of the dollar values will be justified. The dollar value for a given health effect is, of course, constant and therefore generally applicable.
However, there also may be a tendency to apply these values to esses in which the-exposure conditions are not sufficiently similar to justify tha broader application. For example, the dose effects from transuranics differ from those from LWR efflu-ents and equivalent dollar-per-man-rem values would not be applicable. Therefore, the rule making proceeding should clearly define the technical limitations on the transferability of the dellar-per-man-rem and dollar-per-man-thyroid-rem to other exposure sources.
Issue 1. Alternative 1: Institute a rule making proceeding to establish the dollar value of reduction of radiation doses from l
LWR effluents only.
l Pro: (a) Consistent with existing regulations which require l
application of a dollar-per-man-rem value only in the j
case of LWRs.
(b) Numerical guidance on design objectives for achieving ALARA levels for exposure of individuals have been established in the NRC regulations for these facilities.
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lTh2 Commissioners (c) Would not affect current licensing actions because an analysis of cost-effectiveness using a dollar-per-man-rem value is already required.
(d) Requires less time and staff resources than Alternative 2 since a completely new environmental impact statement i
would not be required under NEPA. WASH-1258, the Appendix I Environmental Statement, could serve in part as a basis for the EIS if this alternative is adopted.
Cen: (a) Values of dollar-per-man-rem or dollar-per-man-thyroid--
rem might be misapplied to other organs.
(b) If dollar-per-man-rem or dollar-per-man-organ-rem values were needed for use in other applications, additional rule making might be required.
Issue 1, Alternative 2:
Institute a rule making proceeding to establish the dollar valua of a reduction of radiation doses from effluents of LWRs and other NRC licensed activities.
Pret (a) Would provide a uniform method of /ddre: wing the cost-effectiveness of reducing exposures frca all NRC licensees.
(b) Would eliminate the possible need for additional rule making proceedings for other applications.
Cen: Additional time and resources would be required for ALARA determinations (rule making proceedings) and for the prepara-tion of supporting environmental statements for these other classes of radiation dose sources.
Diccus-ion of In ue 2. EPA Pertielpation:
EPA is developing Federal guidance on the methodology to be used in determining as low as reasonably achievable radiation exposure levels.
This guidance is not believed to be directed toward the determination of specific dollar-per-man-rem values. An EPA contract with the National Academy of Sciences to develop method-ology is expected to be completed within six months. Federal guidance from EPA is not expected to be issued until 1977.
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!:The Commissioners '
i Issue 2. Alternative 1: Conduct rule making proceeding without l
formal coordination with EPA.
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i Pro: (a) The rule making would not involve dual planning and
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direction and therefore could proceed more rapidly.
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. (b) The Commission would have greater flexibility in its j
decisions.
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(c) ' EPA could be a participant rather than a co-sponsor.
Con: (a) Proceeding separately could give the external appearance-l of duplicative and uncoordinated activities.
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(b)~ EPA could issue Federal guidance which might require l
modifications to the approach used'by NRC and ause l
delays in the proceedings or in subsequent lir sing actions.
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Issue 2. Alternative 2: 'Ask-EPA to co-sponsor a public eating to gather information.
Pro:'(a)- Provides a mechanism for developing consistent informa-tion to be used as a data base by'NRC in writing regula-l tions and by EPA in developing Federal guidance..
(b) The time required to coordinate a public meeting with EPA would probably be less than the delays which might be required to incorporate EPA guidance derived from a separate data base.
(c) EPA policy level management has responded favorably to l
NRC suggestions of a joint public meeting.
Con: (a) The guidance which EPA plans to issue on ALARA exposure levels is much broader than NRC's interests. This will make coordination of a hearing difficult though not upmanareable.
(b) There may be philosophical disagreements between NRC and EPA which could tend to restrict the Commission's decision flexibility sad delay promulgation of an jL effective NRC rule.
- ecoussendation:
That the Commission:
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l (a) ' Approve the initiation of a rule making proceeding to establish the dollar value of reductions of radiation doses 1
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from LWR effluents only (Issue 1, Alternative 1) and ask l
EPA to co-sponsor a public meeting to gather information (Issue 2, Alternative 2).
(b) Note 1.
An early notice of proposed rule making similar to Enclosure "A" will be published in the FEDERAL REGISTER allowing 60 days for public comment; 2.
That a public announcement such as Enclosure "B" will i
l be issued; l
3.
That the above documents (FEDERAL REGISTER notice and public announcement) are subject to negotiation between NRC and EPA staff with respect to precise wording.
If l
subatantive changes result, the revised documents will l
be resubmitted to the Consnission for approval prior to publication.
Coordination:
The Offices of the Executive Legal Director, Nuclear Reactor Regulation, Nuclear Regulatory Research, Nuclear Material Safety and Safeguards, and Inspection and Enforcement concur in the recommendations of this paper.
Discussions between the Director, Office of Nuclear Reactor Regulation, and the EPA Assistant Administrator for Air and Waste Management indicate that EPA will be responsive to an NRC initiative to cooperate in a joint public meeting.
h Robert B. Minogue, Director j
Office of Standards Development FaTelosures:
i "A" - Draft FEDERAL REGISTER Notice "B" - Draft Public Announcement "C" - Procedural Options "D" - Detailed Discussion of Alternaeives y
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2' dB w3d-b ENVIRONMENTAL PROTECTION AGENCY AND
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NUCLEAR REGULATORY COMMISSION C&a.=3 tr]
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(40 CFR PARTS XXX AND YYY AND 10 CFR PART 50]
ScK38/G AuM4 j
Solicitation of Public Comment on Methodology for Performing Cost-Benefit Analyses of Reductions in Radiation Exposure.
[The following introductory section might be rewritten by EPA to state.its interest in this proceeding.]
Existing Federal guidance requires that every reasonable effort should be made to keep radiation exposures as fac below Radiation Protection Guides as practicable. This guidance is consistent with the recossmendations of the National Council on Radiat.'on Protection and Measurements (NCRP) and the International Commissioc. on Radio-
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logical Protection (ICRP).
In recent years, efforts have been made to determine "as low as practicable" (in the terminology of the NCRP) or "as low as is reason-ably achievable" (using the ICRP terminology) levels for radiation expo-sure by performing detailed quantitative analyses of the benefits j
attained and the costs incurred in order to achieve different levels of reduction in these exposures. Examples of these analyses include the basis for the Nuclear Regulatory Commission's (NRC) recent amendments to 10 CFR Part 50, adding Appendix I, and the basis'for the Environmental Protection Agency's (EPA) proposed generally applicable environmental I
l Enclosure "A"
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radiation standards for the uranium fuel cycle.
The use cf th2s2 cost-risk-benefit analyses in setting radiation standards is expected to increase in the future.
The Environmental Protection Agency has the function to advise the President with respect to radiation matters, directly or indirectly affecting health, including guidance for all Federal agencies in the formulation of radiation standards. This Federal Radiation Council authority was created by Public Law 86-373 (42 U.S.C. 2012(h)) and transferred to EPA by Reorganization Plan No. 3 of 1970. The EPA believes that consistene methodologies should be employed by all Federal agencies in performing cost-risk-benefit analyses of radiation exposure reductions.
In order to implement this goal, the EPA is presently sponsoring studies of these methodologies with the objective of developing guidance for all Federal agencies on the methods and considerations to be employed in conducting these cost-risk-benefit analyses.
The NRC specified, in its opinion on Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Practicable" for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents, interim monetary values of the worth of radiation exposure reduction to be employed in cost-benefit evaluations of radioactive waste treatment system additions. The interim values bublishedforcommentas40CFRPart190intheFEDERALREGISTERof l
May 29, 1975 [40 FR 23420].
2 As published in the FEDERAL REGISTER of May 5, 1975 [40 FR 19439).
' Enclosure "A" 1
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l wara $1,000 p2r man-rem reduction in tha p:puletion dessa rsc2ivrd by the whole body and by the thyroid gland.
In the NRC view, the record of
'that rule making proceeding did not provide an adequate basis upon which to select a specific dollar value for the worth of radiation exposure reduction. The interim values were selected to represent conservative values compared with previously published values.
The Commission stated in that opinion its intet. tion to conduct, at the earliest prac-ticable date, a separate rule making proceeding to establish appropriate i
monetary values for the worth of a reduction in the radiation dose received by population groups.
Both the EPA and NRC recognize that the effort by EPA to establish uniform Federal guidance for performance of. cost-risk-benefit analyses and the effort by NRC to establish an appropriate monetary value for radiation exposure reductions involve many similar considerations. In order to avoid duplicative efforts in addressing these two areas, the EPA and the NRC have decided to hold a joint public hearing and to jointly solicit early public comment and data relevant to these topics.
The agencies believe that this joint effort will provide opportunity for public involvement and a broader data base for use by both agencies.
i A joint public meeting to solicit comments will be held in late May or I
early June of 1976.
The exact details of this meeting will be announced in the FEDERAL REGISTER.
t Enclosure "A" l
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F311owing thic me2 ting, tha twa Agencies (NRC and EPA) will publish a summary of the material presented containing the conclusions which may be drawn from the data and identifying the areas where additional information is required.
[A Section describing EPA's data needs for preparing Federal guidance could be inserted here.]
Information Needs for Establishing a Monetary Worth for the Cost Associated with Radiation Exposures As stated in the Nuclear Regulatory Commission's opinion on the numerical guidelines for achieving as low as is reasonably achievable effluent releases for light-water-cooled nuclear power reactors, it is the Commission's view that the costs and benefits of radioactive effluent control' systems can be most usefully appraised when expressed in commensurate units, and that the most appropriate unit would seem to.be units of money.
The Comnission also appreciates the potential usefulness_of this value in the comparison of the environmental and public health impacts of nuclear power with those impacts which result from other energy sources.
The Commission would welcome suggestions on other possible units of equivalence or other methods of weighing and costs and benefits.
3 The change in terminology from "as low as practicable" to "as low as is reasonably achievable" was proposed by the Commission in a notice which appeared in the FEDERAL REGISTER of August 6,1975 (40 FR 33029).
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l Enclosure "A" I
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The Commission recognizes that the determination of a monetary value for the worth of radiation exposure reduction will entail the consideration of aesthetic, moral, and human values which are usually regarded as being inestimable.
It is possible that various individuals or social groups may hold widely differing perceptions of how these factors should be appraised. Eecause of these considerations, the Commission welcomes comments and opinions on the desirability of its proposed course of action on this matter and suggestions on how these considerations should be incorporated in this rule making proceeding.
The Commission is proceeding with ALARA determinations for many sources of radiation exposure.
Combining the specification of a dollar / man-rem value which should be independent of control technology and the determination of the practicability of exposure reductions which is dependent upon technology could delay both efforts.
There-fore, the Commission has tentatively decided to limit initially the scope of its rule making proceeding subsequent to the public meeting to the determination of a dollar / man-rem and dollar / man-organ-rem values for application to light-water reactor effluent control systems.
These values might be applied to other sources of radioactive materials discharged to the environment in future rule making actions.
- However, additional applications would not be undertaken until ALARA require-ments have been established by rule making proceedings for the control of individual exposures. The NRC solicits comments or suggestions regarding this tentative decision.
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' Enclosure "A" 4
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The mon tcry valu2 fer th2 vsrth of a raductica in radictica esposure can be expressed as the product of'two factors. The first term is a risk factor that denotes the potential incidence of bio-logical damage per unit of radiation dose.
The second term is a cost-per-risk factor that denotes the cost to society associated with the manifestation of this effect. This relationship can be expressed by the following equation:
Monetary
[
(incidence of effect, (Monetary cost of cost man-rom all effects per man-rem) incurring effect)
A similar relationship for potential effects from irradiation of individual organs or tissues might also be postulated. The Commission has tentatively decided that both factors should be examined by the NRC staff in this rule making proceeding in order to arrive at the monetary value for population exposure reductions. Comments on this tentative approach are also solicited by the Commission.
The effects of radiation could entail potential ill health or loss-of-life and the cost factor might represent the cost associated with human suffering or death. It is recognized that a monetary cost for the loss of human life or health is often implicitly assumed and has been used explicitly for the evaluation of certain public projects and that such values might be deduced from a variety of sources.
The Commission proposes to collate, compile, and evaluate these existing monetary valuations in order to arrive at an appropriate value for the l
cost factor in the above equation.
i Enclosure "A" l
The worth of a single ideittifiable human life is immeasurable and expenditures to save a particular individual may far exceed any reasonable value deduced from any of the foregoing information. The risks which may be associated with radioactive effluents from normal operation of nuclear power reactors pose an extremely small incremental risk to any real individual. The radiation effects of principal concern involve considerations of the population-integrated radiation dose -- the summation over a number of individuals receiving small incremental exposures. The effects which might result from these doses are of a statistical nature and might be manifested only when large population groups are involved, even for the supposition of a linear, dose-rate-independent, nonthreshold dose-effect model. The overall risk that might be associated with radioactive effluents from normal operation of nuclear power activities should comprise only a very small fraction of the risk that would be projected from exposure to the natural radiation which exists in our environment.
Solicitation of Comments and Pertinent Information - Conenents, recommendations, and data submissions relevant to the determination of a monetary cost for the effects of radiation exposure are invited from all interested persons.
Specifically, comments are requested on the following questions:
[The specific questions might be modified or additional questions could be added relating to EPA's data needs. Such changes would
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Enclosure "A" t
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4 reflect EPA's broader responsibilities for hazardous material effluent control and Federal radiation protection guidance.]
1.
Are there methods for performing cost-benefit balances which are preferable to establishing a monetary equivalence to the cost of potential radiation induced injury?
2.
Are there alternative methods for cetting the monetary value for the worth of reductions in radiation exposure which do not involve the equation:
Monetary (effects), (Monetary cost)7 cost dose dose effect 3.
What methods should be used in deriving the dose-to-risk (effects / dose) factor?
a.
Are there more suitable methods for describing radiarion dose-effect relationships than the linear, dose-rate-independent, conthreshold dose-effect model?
b.
How should the differing radiosensitivities of various organs and tissues be considered?
c.
How should potential genetic effects on future genera-tions be compared with potential effects to current populations?
d.
How should risk estimates based upon different methodologies be compared and combined?
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How should changes in radiosensitivity with age, l
health, sex, etc., be included?
i I Enclosure "A" e
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- 4. ' How shall the cost-per-effect factor be derived?
i a.
What considerations should be included?
b.
What data sources might provide value-of-life-saving estimates?
c.
Should adjustments be made for inflation or other changes in the worth of the U. S. dollar in evaluating life-saving expenditures?
d.
How should compensation payments for injuries ;r loss-of-life be evaluated ir estimating life-saving or injury-prevention costs?
5.
How shall the cost-per-effect and effect-per-dose factors be combined?
a.
Should the cost-per-effect for effects which might occur late in life be subject to a discount rate?
b.
How should the cost for treatment and' morbidity and mortality censiderations be used in weighing fatal, fatal-unless-treated, and non-fatal biological effects?
c.
How should inequities in the cost-benefit relationship (tha risk or cost being borne by one group and the benefits accruing to another group or to society in general) be addressed?
6.
What criteria should be used for the selection of appropri-see dollar / man-rem and dollar / man-organ-rem values?
a.
How should other risks which are accepted by society be employed in the selection of these values? Enclosure "A" 1
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F b.
Should tha rick from.n turclly-occurring radiction or radioactive materials be employed in setting an acceptable risk from man-made radioactive materials?
c.
How should differences between voluntarily assumed risks and imposed risks be judged?
All interested persons who desire to submit comments, suggestions, or technical data bearing on the foregoing matters, or other relevent information should send their comments either to the Secretary of the l
Cosmission, U. S. Nuclear Regulatory Commission, Washington, D. C.
20555, Attention:. Docketing and Service Section or to the Director, Criteria and Standards Division (AW-560), Office of Radiation Programs, U.S. Environmental Protection Agency, Washington, D.C.
20460 on or before (60 days after publication in the FEDERAL REGISTER). Copies of the comments received may be examined at the Nuclear Regulatory Commission's Public Document Room at 1717 H Street, N.W., Washington, D.C. or EPA's Freedom of Information Office, 401 M Street, S.W.,
Washington, D.C.
(Sec. 161, Pub.L.83-703, 68 Stat.948 (42 U.S.C. 2201); Sec. 102, l
Pub.L.91-190, 83 Stat. 853 (42 U.S.C. 4332); Sec. 201(f), Pub.L. 93-l 438, 88 Stat.1243 (42 U.S.C. 5841)).
For the Nuclear Regulatory Commission.
Samuel J. Chilk Secretary to the Cor: mission For the Environmental Protection Agency.
l Roger Strelow Assistant Administrator for Air and Waste Management
. Enclosure "A"
NRC-EPA TO CONDUCT PUBLIC MEETING ON MONETARY WORTH OF REDUCING RADIATION EXPOSURES FOR USE IN. COST-RISK-BENEFIT ANALYSES The Nuclear Regulatory Commission (NRC) and the Environmental Protection Agency (EPA) plan to hold a joint public meeting as part of an NRC effort to establish a dollar value for reducing exposures to low levels of radiation from light-water-cooled nuclear power plants and an EPA effort to establish uniform Federal guidance for performance of cost-risk-benefit analyses.
The public meeting tentatively is planned for late May or early June 1976, and the two agencies also plan to jointly solicit public comment and data.
In recent years, efforts have been made to determine "as low as is reasonably achievable" exposures to radiation by quantitatively'analyling the benefits attained and the costs incurred in achieving different levels of reductions in exposure to radiation. This is in keeping with existing i
Federal guidance that every reasonable effort be made to keep exposures to radiation--except those from natural background and medical sources--as.'far below radiation protection guides as possible.
)
i On April 30 this year, the NRC announced design objectives for keeping exposures to radiation released in effluents from light-water-cooled power reactors "as low as is reasonably achievable." As part of its decision, the NRC set an interim value of $1000 for reducing exposures by one man-ran to the total population living within 50 miles of a power reactor site.
A man-rem is a measure of exposure to radiation to large groups of people--
l for example, 100 m ia each being exposed to 0.01 rem, or 1000 people each being exposed to.0.001 rem.
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The interim value was based on the record of a public rule making proceeding, but, in the NRC's view, there was not enough information to select a specific dollar value for the worth of further reductions in exposures to low levels of radiation..Accordingly, the NRC announced its intention to conduct a separate rule making hearing.
At the same time, the EPA--which is responsible for preparing guidance for Federal agencies in the establishment of radiation standards-has been sponsoring studies of various methods which could be employed uniformly by all Federal agencies in performing cost-risk-benefit analyses of l
reductions in exposures to radiation.
l In connection with this proceeding, the NRC is seeking information on:
(1) Whether units of money are appro~priate for considering the cost and benefits of radioactive waste effluent control systems and the usefulness of this value in comparing public health and environmental impacts of nuclear power with the same impact of other power sources--or if some other unit er method could be used in weighing these costs and benefits; j
(2) The general desirability of placing some kind of value on further reductions in exposures to low levels of radiation and the views of various l
groups and individuals on the aesthetic, moral and human values involved--
usually regarded as not capable of being estimated or quantified--and how these considerations should be factored into the rule making process; j
(3) The NRC is considering "as low as is reasonably achievable" deter-minations for many other nuclear fuel cycle sources of radiation exposure and which are dependent on various control technologies. The NRC believes i
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that the proposed rule making proceeding which deals primarily with the potential healt costs of radiation exposure should be separated from questions of the practicability of control technology. Views on how these considerations should be factored into the rule making process and the Commission's determination to limit this proceeding to light-water-cooled power reactors are solicited; (4) Expressing a dollar value for the worth of a reduction in radiation in terms of two factors--(a) ths potential incidence of biological damage per unit of exposure to radiation, rad (b) the cost to society of the i
biological damage; (5) The use of varying life-saving expenditures (such as transportation safety and expenditures to control other pollutants) which have been made by society in the past; and (6) Relating the biological effecte of radiation to large groups of i
people rather than to a single individual.
A list of specific, related questions on which comments, suggestions or technical data are being sought is batag published in the FEDERAL REGISTER Comments in response to the Eotice should be submitted on within 60 days. They should be addressed to the Secret.ary of the Commission, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, Attention:
Docketing and Service Section, or to the Director, Criteria and Standards l
Division (AW-560), Office of Radiation Programs, Invironmental Protection Agency, Washington, D. C. 20460.
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e PROCEDURAL OPTIONS l
There are several alternative methods which could be used to solicit public input for the rule making. These procedural alternatives are l
subordinate to the two main issues of scope and EPA participation.
The existing estimates for a dollar / man-ren value provide an insufficient basis for an' assessment of the monetary worth.
The existing dollar / man-res i
estimates are incomplete since the risk estimates are either' based upon loss-of-lifeassociatedwithalethakdoseorestimatesoftheincidenceof chronic injury such as carcinogenesis without consideration of other chronic somatic effects, life-shortening, or genetic effects to future generations.
The cost-of-injury estimates are similarly incomplete.- These estimates are based upon:
(1) accident compensation payments (which involve compensation for injury or loss-of-life which has already occurtcd rather than for l
l prevention of injury); (2) national expenditures for health research (which.
represent only a portion of the costs associated with injury); or (3) the present worth of lost earnings.
This last approach might be suitchie for assessing life-insurance coverage, but does not consider the value of an individual as a consumer and the social value inherent in a person.
In order to develop a credible basis for the monetary cost of radiation injury, all of these deficiencies in the published values should be corrected.
This process will involve considerable staff time in order to keep aware of current developments, acquire necessary data on costs of injury and 4-l i
i Enclosure "C" i
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l dose-risk relationships, cnd intstgrats thsos divarca fcctero into o echarant and supportable basis for the proposed rule.
The staff believes that adequate time for public comment is essential to the proper completion of this rule making proceeding. The need to incorporate aesthetic, moral and human values into these considerations has l
been recognized'by the Comunission in its decision on Appendix I.
- Yet, l
these intangible factors are generally regarded in economic studies as "externalities" and there are no standard methods for their incorporation l
into such studies. Thus, the NRC in this effort will be venturing into unexplored areas and pioneering in the development of methods for quantifying social values. The staff believes that such considerations can be addressed only with a broad opportunity for public input.
Dis,cu,ssion of Alternatives It should be noted that a Commission decision to involve EPA (Alter-native 2 to Issue 2) involves EPA agreement on the role of their involvement.
Discussions with EPA indicate that EPA would be favorable to sponsoring a l
l joint public meeting to solicit information and input.
EPA is developing general Federal guidance on the methodology to be employed in performing cost-benefit studies of radiation control measures. The EPA efforts are not devoted toward establishing a specific dollar / man-rem value.
For this reason, EPA probably would not be favorable toward full co-sponsorship of the rule making proceeding including the determination and acceptance of a common dollar / man-ren value. A Commission decision on Issue 2 favoring EPA I Enclosure "C" I
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_ 7 Anvolvement, limits the range of procedural options to a public meeting to solicit information.
4 There is no alternative presented for proceeding without a public meeting or other form of hearing. The Commission stated in its opinion on i
10 CFR Part 50, Appendix I that:
1 "W propose, therefore, at the earliest practicable date to conduct a rule making hearing to establish appropriate monetary values for the worth of reduction of radiation doses to the 4
population."
The following proposed procedural alternatives apply only to a rule j
making proceeding restricted in scope to IRR effluents (Alternative 1 of l
Issue 1). The schedules for other alternatives to Issue 1 are discussed in Enclosure D.
Revised Schedul.e i
At the Commission's direction, ths staff has critically re-*vamined the proposed schedule (October 24, 1975 rstefon). A,six-month reduction in the schedule was achieved by reduction of the period to incorporate i
public commertts on the proposed rule, by concurrent r riew of the initial comments with EPA and preparation of the proposed rule together with concurrent, rather than sequential, completion of the technical bases, and by reducing the number of interoffice reviews from two to one. The revised schedule is shown as the November 3, 1975 revision and is the version presently I
3-Enclosure "C" 4
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recommended by the staff. This schedule also reduces the period of perform-ance of the risk-perception contract from twelve to nine months.
Alternative This option does not involve EPA participation.
There would be no public comment prior to developing a proposed rule other than the initial 1
solicitation of comments in the advance notice. The completion time for determining the monetary value and preparation of the proposed rule has been reduced. This option reduces the schedule by only one month. The primary reason for only a small change in the overall schedule, despite a i
significant reduction in the time allotted for the technical development, j
is due to the procedural requirements of an NRC rule making proceedings and i
the original concurrent scheduling of both activities. The hearing would be after the publication of the proposed rule, six months later than the public meeting scheduled in the recommended (11/3/75) version.
, Enclosure "C" t
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1975 CY.
1976 -
CY 1977 IMlJ lJ l Al SlOINID 'J l FIMI AlMl dl J l Al SIOlNID J l FIMI A IM I J I J l A ISIOINID tlT3." '
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i DETAILED DISCUSSION OF ALTERNATIVES 4
Issue 1 Limitation of the Rule Making Proceedina to Light-Water Nuclear Reacto? Effluents - The alternatives for the scope all involve reductions in the radiation dose received by the general population from radioactive materials reisased to the environment-as routine effluents. These alternatives are:
1.
Limit the scope to light-water nuclear power reactor effluents, de 2a. Expand the scope to include routine effluents from all fuel cycle facilities including uranium mills, conversion, enrichment and fuel fabrication plants, spent fuel reprocessing plante, waste storage or disposal facilities, and mixed-oxide fuel fabrication and scrap recovery facilities.
2b. Further expand t.he-scope to consider effluent releases from all byproduct material and source material licensees including industrial research laboratories, universities, hospitals, radiopharmaceutical manufacturers, etc.
The monetary value of the health costs associated with radiation
. doses which are not similar (in terms of individual risk due to dose and dose rate diffarences) might not be the same as the dollar value assigned l
to the dose from routine effluents.
In principle, however, a cosmon i
monetary value for the cost of radiation damage, based solely upon the j.
costs associated with potential health effects, should be applicable to the l
aanlysis of the cost-effectiveness of any effluent treatment system.
Enclosure "D" f
~
r e
Bowever,thetypeofhealtheffectprod$ced(andconsequently,the
~
associated monedary cost) would depend upon the' organs irradiated.
Limitation of a dollar / man-ren value to whole body exposures overlooks the selective concentration of various radionuel(des by individual organs and the different radiation sensitivity o different organs.
For light-water reactors, the principal exposure pathways are:
(1) external' irradiation from the gaseous effluent and from material deposited on the ground or with' sediments, (2) ingestion of aquatic food organisms containing cesium and (3) thyroid irradiation from radioiodine discharges in gaseous and liquid effluents. Except for radioiodine, the principal dose from these pathways is delivered to the total body. This would not necessarily be the case for other fuel cycle facilities. Plutonium and other transuranics would primarily irradiate the lungs, GI tract, and the bone. Uranium particulates or gaseous uranium hexafluoride also would selectively irradiate these organs rather than producing a uniform dose to the total body. Particulates and radon emissions from uranium mills and mill tailings piles would irradiate the lungs, and, to a lesser extent,'.the GI tract, and bone. Therefore, while the monetary j
cost of a particular effect such as lung cancer, might be consistent and l
independent of the source, the dose distribution in the body is not independent of effluent composition and, consequently, the_ type and
~
number of potential. health effects would depend upon the radiosensitivity of the organ irradiated. This would require the development of a monetary i
i 1 Enclosure "D" i
i
u costs frr the d s3 to ecch crgan. Fcr souress cther thin light-watar reactors, the whole body and thyroid doses may not be the principal consideration.
. The principal procedural problems. associated with a broad scope of the rule making arm (1) performance of cost-benefit or value-impact i
analyses for the regulation itself and (2) determination of the methods for implementation of the regulation in licensing actions. It is princi-l pally because of the considerable delays which may be necessitated in order to provide adequate support for discussion of these issues for sources other than light-water nuclear power reactors that the staff recommends a very restricted scope for the rule making.
Requirements for Cost-Benefit or Value-Impact Analysis of Proposed Regulations - The impact of a specific dollar per man-rem value for the worth of radiation exposure reduction is primarily expressed in terms of the added costs for effluent control systems or other mechanisso required to achieve a cost-benefit balance. The. principal value of a specific i
l dollar / man-res figure is reflected in terms of the reduction in potential l
ill health afforded by a cost-benefit balancing. This latter value l
would be inherent in the numerical value of the dollar / man-rem unit.
The economic impact, however, would be reflected in an analysis of the total national costs for affluent control systems or other exposure l
reduction measures and the incremental additional cost to the power consumer, These costs are not inherent in the dollar / man-rem value. A i
- 3'-
Enclosure "D" l
4
detailed study of applicable effluent control methods would be required
~
for each source of exposure in order to determine the total and incre-mental costs of each additional system, the doce reduction afforded by j
each system, and the resulting incremental dollar / man-rem value. Only from this analysis could the total cost per facility, the total nscional cost for all facilities of a particular type, and the incremental cost to the power consumer or user be associated with a specific dollar / man-rem value. This process is equivalent to preparing an environmental statement for as low as is reasonably achievable effluent releases (or exposure reductions) for each and every source under consideration.
It is, therefore, equivalent to conducting an ALARA determination for each source class.
The population doses effluent treatment system costs associated with dollar / man-rem values ranging between $100 and $1000 per u n-ren were presented in the staff's concluding statement for the Appendix I rule =mk hg proceeding. The environmental statement (WASH-1258) and hear-ing for this regulation also explored the practicability of gaseous and liquid radioactive waste treatment systems for light-water-cooled nuclear reactors. The staff believes that this record would serve as a base for the proposed rule making proceeding and that a totally new environmental impact aralysis and environmental statement would not be required if the i
scope 'of the proceeding were restricted to light-water reactors.
If the Commission elects the recommended option, two supplemental reports to WASH-1258 would be prepared. The first report would contain a summary
. Enclosure "D"
'o and analysis of the public commente and data submitted in response to the advance notice of proposed rule making and the material presasted in the public hearing.
If the commission proceeds jointly with EPA, this report would be prepared in cooperation with EPA. The second report, prepared independently by NRC, would contain the technical basis for the determination of the dollar / man-rem or dollar / man-organ-rem values and the comunents received on the proposed rule. A brief analysis of the costs and'environanntal impact-w; 3 7,.
of the recommended value would be presented in this repor6. '{,
,,f 1
If the Commission elects to expand the scope ofthe rule making pro-l caeding to the determination of dollar / man-rem values for application to other sources, additional resources would have to be allocated for the specification.of ALARA requiremento for design objectives and limiting conditions for operation for individual doses and for the preparation of an environmental statement addressing the impact of these requirements.
Preliminary estimates of the additional resources and time required to prepare these analyses are presented in Table A.
Expanding the scope' of the proposed rale making proceeding to include affluent limitations for other nuclear fu.?, cycle facilities could double the completion time and require approximately one million dollars in extra contract funds. Further expansions would lengthen the completion time and require the additional resources as shown in Table A.
I l
l i
! Enclosure "D" k
F.
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Tab 1'e A l
SUWARY OF ESTIMATED RESOURCE REQUIREMENTS FOR ALTERNATIVES TO ISSUE 1 Technical Duration Staff-effort Support Alternative (Months)*
(Man-years)*
($1,000's)**
1.
LWR Effluents 24 3
300 I
2.
Fuel Cycle Facilities 54 7
1120 3.
By-product and source material licenses 60 9
500 l
- cumulative - includes preceding option j
- per alternative (not cumulative) l
- 6.-
Enclosure "D" i
\\.
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f.O Th3 tumb:r cad compicxity cf tha icsu:s which would h va to ba cddrascrd Some of these if rule making proceeding were expanded would be enormous.
issues that might be raised for the fuel cycle include:
' 1.
The economic justification for fuel reprocessing;
)
The health hazards of plutonium and the " hot-particle" issue; 2.
3.
The worldwide Lapact of long-lived radionuclide discharges; 4.
The practicability of effluent treatment systems for:
a.
uranium mills b.
conversion plants
~
c.
enrichment plants d.
fuel fabrication facilities i
spent fuel reprocessing pla'nts s.
f.
waste storage facilities i
g.
plutor ium fuel cycle facilities.
Coatrol uf uranium mill tailing pile releases and the practicability 5.
of stabilization of these piles.
The staff believes that these or other additional considerations would seriously delay the proposed rule making proceeding.,A proceeding which addressed so many important and controversial issues might prove to be un=mnageable.
Implementation - Sound and effective. procedures are required in order to implement a new regulation in licensing actions, inspections, and enforce-Based upon experience with the development and implementation ment actions.
of Appendix I, the staff believes that the following problem areas would have
)
to be considered as they relate to each effluent source classification:
l Enclosure "D" r l
~
L...
,:r e.
f (1) Limitaticas to the geographic distribution of doses j
i The Appendix I rule limits the assessment of population done to a 50-mile radius of the facilicy. If the scope of the rule making proceedir.g is 1
l extended to other fuel cycle facilities, this limitation would have to be reevaluated due to the potential global implications of the release of long-lirad radionuclides, particularly from spent fuel reprocessing plants or mixe4 (plutonium-uranium) oxide fuel fabrication plants. World-wide dispersion of these effluents would have to be evaluated and this would require the development of global transport models.
In addition, regional dispersion of radon and its daughters might have to be evaluated for uranium mills.
(2) Temporal limitations to dose Hany effluents from fuel cycle facilities have extremely long half-lives, for example:
iodine-129 (17 million years), and uranium-238 (4.5 billion years). The long-term behavior.of these radionuclides in the j
i environment is not known and could become ari issue in this rule making proceeding.
j By-Product or Source Material Licenses (1) Cost of Acquiring Information by the Licensee or Applicant -
I Impler.entation of the regulation would requira data in order to j
calculate the population dose, these dat:a would include the composition and i
magnitude of effluents and the determination of the exposure pathways for i
the material to reach humans.
i
, Enclosure "D"
]
I
. - -.. - -.~.- - -.
- a t g t-0 An exampia of the difficulties in this regard are licenses which permit disposal of small quantities of radioactive materials to sanitary sewer systems. Knowledge of the sewer systems, the sewage treatment facility and its environs would be required to, perform the dose calculations.
The cost of obtaining this information in order co show that population doses l
were in compliance or were insignificant could easily exceed the dollar / man-ram value.
l (2) Implementation in Licensing Actions i
Methods and procedures for reviewing and evaluating an applicant's cost-benefit analysis would have to be developed. Although the additional staff time to verify the applicant's analysis might be relatively small for
~
1 l
each license review, the additional time or NRC staff requirements required l
l to process some 8000 licenses applications or renewals annually could be significant and would have to be evaluated.
Is_s.ue,2 (EPA Participation) l Pro: The Pederal Radiation Council was established by statute in 1959 l
(Public Law 86-373,
.'? M.C 2021(h)). A major function of the Council I
was to "... advise the President with respect to radiation matters, directly or indirectly affecting health, including guidance for all l
Federal Agencies in the formulation of radiation scandards and in the establishment and execution of programs of cooperation with l
States...."
This authority was transferred to EPA by the Reorganiza-1 I
tion Plan No. 3 of 1970 (Section II, paragraph 7).
l
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Enclosure "D" r.
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Under this authority EPA could reco-end to the President methods to be employed in performing cost-benefit analyses of radiation exposure.
These methods, if approved by the President would be issued as Federal guidance.
If this guidance differs appreciably fro.n the methods used I
by MRC, the revisions necessitated in the NRC approach may lead to l
a delay in the proposed rule =mking proceeding.
A joint public meeting could provide an example of interagency coordi-nation rather than an apparent duplication of efforts. There are I
several potential problems which would have to be resolved concerning the conduct of a joint meeting. Coordination of activities might
)
extend the time required for the rule making proceeding by 2 to 3
{
months. However, possible delays from a' joint meeting probably would be less than the increased time required to modify NRC methodology to conform to potentially conflicting Federal guidance developed by EPA.
EPA initiated a contract with the National Academy of Sciences, National Research Council (NAS-NRC), in February of 1974, to investigate and propose methodology for performing cost-benefit studies of radia-tion exposure reduction. This report is scheduled for completion in February 1976.
EPA is also doing in-house work on Fedetal guidance for r
maintaining radiation exposures as low as practicable.
Draft Federal i
siddance was scheduled for preparation by December 1975, but we under-i stand that this effort has been delayed.
- . Enclosure "D" 9
w-
,m y
.._i
1 x
?.'
Con: EPA would no't be able to issue guidance without an opportunity for the Commission.and the NRC staff to review and ' comment upon it prior to its acceptance as Federsi guidance. The impact of this guidance on the rule making proceeding could be addressed in the NRC comunants on the EPA draft.
The EPA could be a participant in a rule making proceeding and present its position without being a joint sponsor. The EPA poeition along with the views of other persons, would be considered by the Commission in its findings.
The documents issued by EPA's Office of Radiation Programs have generally tended to use the linear, dose-rate independent nonthreshold dose-effect hypothesis without adequate qualification of the uncertainties and probable. conservatism inherent in that hypothesis. This approach makes it difficult to provide adequate perspective to the uncertainties inherent in extrapolating effects from high doses and high dose rates l
to the low doses and dose rates associated with effluent releases during routine operation.
l l
. Enclosure "D" i
I I
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a t
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