ML20202F498

Submits Addendum to SECY-75-679,to Supplement Info Concerning Two Issues Re Opinions of Outside Organizations & Individuals Concerning Scope & Methodology & Risk Perception as Possible Factor to Be Considered

ML20202F498
Person / Time
Issue date:	03/18/1976
From:	Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT
To:
References
SECY-75-679A, SECY-75-679A-R, NUDOCS 9902040076
Download: ML20202F498 (11)

Text

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v u c>w.=a b UNITED ST ATES k NUCLEAR REGULATORY COMMISSION i S " 679^

March 18, 1976 f LICY 5555lON iT5M For: The Commissioners 1 From: Robert B. Minogue, Director, Office of Standards Development Thru: Executive Director for Operations

Subject:

ADDENDUM TO SECY-75-679: PROPOSED RULE MAKING PROCEEDING FOR COST-BENEFIT ANALYSES OF REDUCTIONS IN RADIATION EXPOSURE

Purpose:

To supp)ement SECY-75-679 with information concerning two issues:

(1) opinions of outside organizations and individuals concerning scope and methodology, and (2) risk perception as a possible factor to be considered.

Di-cussion: At Policy Session 75-65 the Commissioners asked staff to solicit l cutsideopinionsonthescopeofproposedrulemaking(Issue 1below[  !

Additionally, PE has raised questions about the appropriateness of risk perception as a possible factor to be considered in the rulemaking (Issue 2 below).

Issue 1: Outside Opinion We have completed informal discussions with outside organizations and individuals as requested by the Commission in Policy Session 75-65 on SECY-75-679 (December 9, 1975). The final list of persons or organizations contacted (Enclosure A) was based on the staff recom::.endations in SECY-75-715 (December 15, 1975); addi-tions to the list approved by the Commissioners on January 21, i 1976; and additional individuals or groups suggested by the l

respondents.

Following is a listing of the questions we asked and our character-

, ization of the answers received:

Question 1. Is it advisable to specify a mone;;ary equivalent to l

the cost of radiation injury in terms of a dollar / man-rem value or 1r there a better method of arriving at a cost-benefit balancing?

1. No one suggested what they thought to be a better method for cost-benefit balancing. Two industry respondents and one j

• Reference Mano Chilk to Gossick - 12/11/75. '

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The Comunissioners l public interest respondent suggested expressing costs on a per health effect basis in order to be able to adjust to new l bioeffects information. One industry respondent suggested a curie limit rather than the cost-benefit analysis.

2. There were three negative responses; the majority favored the application of this concept.

3. Several state and industry respondents, although favoring the l l approach, questioned the advisability of developing or apply- j

! ing a monetary value in a regulatory context. One state i suggested placing the dollar / man-rem value in a Regulatory i Guide rather than in a less flexible regulation.

4. One industry respondent suggested waiting until more experi- )

ence was gained using the interim $1,000/ man-rem value. l Another industry respondent suggested adopting the interim '

value without requiring a technical justification for it. j l

l S. Two respondents (one state and one university) suggested i j involving EPA in order to arrive at a general value applicable l to all sources of radiation, especially for medical X-ray exposure which is not in NRC's jurisdiction.

Question 2. Should a general value, applicable to any source of radiation exposure be developed or are there factors which would suggest that the applicability should be restricted to specific i sources?

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1. The responses did not pr.71de a clear cut resolution of this question.

2. The state responses were evenly divided. The states that favored a general va.lue believed that it would provide valu-able perspective on where radiation control resources should

be allocated.

3. InJustry respondents believed that a general application of values derived is inevitable.

4. Among the factors that were raised for restricting the appli-cability to specific sources were:

a. Differences in the populations that might be affected (local versus world-wide impacts) and differences in the valuation of life in different societies.

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Tha Commissioners b. Indiviaual dose. levels which argue against using the same

'value for effluents and occupational exposure.

c. Different risks as perceived by the public, e.g., a possible willingness to pay more for controlling nuclear exposures than X-rays.

d. Different organs might be affected by different sources, for example the dose distribution among organs is differ-ent for penetrating gamma and X-rays.

Question 3. What factors should be considered in developing a dollar / man-rem value?

1. Only factors indicated by the respondents were noted. These l factors are tabulatted in Enclosure B.

2. In addition to the use of projected health costs, and lost productivity'and earning costs, the following factors were identified:

a. Analysis of the benefits associated with electricity and

( the level of benefit: luxury or necessity (2 responses);

b. Dose level and dose rate effects (3 responses);

c. Considerations of the nature of the' exposed population, particularly in terms of different life values in dif-ferent countries (6 responses);

d. Risk as perceived'by the public or anxiety factors (4 responses);

e. Health costs of other methods of generating electricity (1 response).

Question 4: Should societal expenditures currently made to control

-other sources of health risk-(such as transportation safety) be

considered in the~ development'of a monetary equivalent for radia- j tion exposure? If'so, hoa should this be used? o

1. The responses generally indicated that use of these consid-p--

erstions was valuable. l 4

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2. . ..The responses were split between a direct application in _

. ,fdetermining the dollar / man-rem value and use only for com- 1 b 'parison purposes.

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The replies received by the NRC staf f were expressed as informal l personal opinions and not as of ficial positions of the orge.1za- I tions contacted. '

Issue 2: Risk Perception In a meeting on January 27, 1976, the Office of Policy Evaluation expressed concern about the desirability and usefulness of the Commission sponsoring a study of the subject through a proposed contract to Mitre. The contract has not yet been consummated and OPE raised a question as to the desirability and effe tiventss of such a contract in support of the purposes the Commission had in mind for the rulemaking. OPE also requested that we specifically identify the question of perceived risk versus actual risk as an I l

issue requiring further Commission consideration before its inclusion in the scope of the rulemaking proceeding. This sub-ject was addressed in SECY-75-679 in the draft notice of intent (page 5 of Enclosure "A" to SECY-75-679). We believe this concept incorporates the aesthetic, moral, and human values that the Commission has stated in its opinion on Appendix I of 10 CFR Part 50 should be included in the selection of a dollar / man-rem value in addition to purely actuarial considerations.

The perception of risks is a crucial factor in determining atti-tudes. People generally respond to a threatening situation based upon what they perceive it to be rather than what the actual risks t

are. Some people use this concept to explain adverse pu:lic reaction to nuclear energy. That is, since few individuals in the general population have had experience with radiation, understand the mechanisms of radiation injury, or can evaluate the magnitude of the potential risk, the public perceives the risk to be different than the real or known risk. Because of this lack of experience and understanding, assessment by the general public of the risk due to radiation ir principally determined by the threat as imagined rather than from experience. This would tend to indicate that the public acceptability of the risk from nuclear energy cannot be determined solely by comparison with risks which are currently accepted from other, more familiar hazards such as disease, traffic i

fatalities, etc.

l Studies by Wyler and others (as discussed in H. Otway, "Quantifica-tion of Social Values" in Los Alamos Scientific Laboratory Report LA-4860-MS, Risk vs. Benefit: Solution or Dream?" (1972)) have shown that it is possible to deveJop a Seriousness of 111 ness

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!The' Commissioners 1 i

Rating scale based upon relative ranking of various diseases.

Lenhm=4a and other cancers are perceived to be more serious than i

I other forms of death such as heart attacks and strokes. These two types' of cancer account for approximately half of the projected.

i i radiation-induced health effects estimated from the data of the i United Natiens Scientific Committee on the Effects of Atomic Radia-l tion (UNSCEAR) and the Advisory Committee'on the Biological Effects i j of Ionizing Radiation (BEIR) of the National Academy of Sciences. i i The perceived seriousness of cancer and its association with radia-

{ . tion exposure strongly suggests that risk perception be included as

! a consideration in the development of the cost-benefit equivalence  !

! for radiation exposure control. As indicated in the discussion of j outside comments (Issue 1), several respondents to the staff j survey have indicated that " anxiety" or perceived risk consider- - l

ations should be incorporated into the development of a monetary j equivalent for radiation injury.

We are aware of a large body of literature in psychology and the socisi sciences which deals with the question of risk perception.

Although the development of a model which would permit a numerical assessment of a modifying factor is unlikely, a reistionship between current levels of expenditure to control var; as hazards

.and perceived risks might provide information on the magnitude or significance of such a modifying factor. The staff proposes to explore such relationships. Furthermore, as was implicit in the staff reconsnandation in SECY-75-679, we believe that the. Notice of Intent should solicit public input as to whether and how risk' perception should be incorporated in the setting of a monetary value through rule making.  !

On February 12-13, 1976, the SD Task Leader was permitted to observe the deliberations at The Advisory Committee on the Biolog-ical Effects of Ionizing Radiation (BEIR) of the National Academy of Sciences National Research Council. Impressions gathered from this. meeting indicate that the final BEIR report on cost-benefit analysis for radiation protection will:

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(1) recommend that cost-benefit analyses be extended beyond simple economic considerations to include ethical and social value 1 considerations;

.(2)' adjudge " risk perception" as an "important" factor to be con-sidered in these analyses; )

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lThe Commissioners l

'(3) determine that existing cost-benefit analyses, comparing nuclear and fossil fuel for electricity generation, are useful but incomplete.

The BEIR report probably will not,:  ;

i (1) offer ureful methodology for the determination or incorpora- l tion of socisi and ethical values into cost-benefit analyses; j l

(2) develop an actual monetary value for the man-rem nor advocate that such monet.ization be employed; (3) offer an alternative to (2);

i (4) reach a value judgment on che role of nuclear power versus fossil fuel..

, Coordination: This paper was reviewed by the Offices of Executive Legal Director, i Policy Evaluation, and the General Counsel. OPE comments are attached as Enclosure C; ELD and OGC had no comments. We have  ;

modified the paper to reflect OPE input from a Jan tary 27, 1976  !

meeting as well as their written comments.

ISchedulina: his paper la intended to be discussed with the Commission in connection with its reconsideration of SECY-75-679.  !

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N Robert B. Minogue, Director Office of Standards Development l

l Enclecures:

l"A" - List of Persons Contacted l""B"-TabulationofComments

! C" - OPE Comments i DISTRIBUTION 1

Conunicsioners Cotanicsion Staff Offices

' Executive Director for Operations

, SecrOtariat

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} l I 5ectosure 4 uw= teen Department of necial and maalth services -

' Grege and ladividente Centacted Schert Ut11, emperviser, Sadiatten Cimeral Snit [

i Conferesse of Radiaties Centrei Progree tisectare I-

• Robert u111, Chairman .

Inemat*T ..

, yesterm Interstate Euclear Beerd - Wyatt Regere. Emaintius M rester Asamte ladestrial Forum, ac. - 5. David Earward, Managne g

4 Envireemental Prof --as Southere interstate thaclear board - Emeneth peneth, Enocutive Mancter '

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j unet8- M a Electric Caspeay - William Brown, sammager .

Enviremanatal Effecto FIE systems Divisies ,

! , Pubite lateneet k Gameral Electric Company - Noet skirley, Sealer Licemalag % s. - Union of Caecerned Scientiate - Dr. Henry Readall, MIT i,

Commelidated Utility Creep - uniten A. Redser (comesitant) Consolidated Battomal latervenero - Antheney &atemma (Counsel) 3 anchtal Corporaties - Jane Teoce, Radiation Management Segerviser !8 4

matural seecurces Defemme Ce meal - Dr. Thenne cachaea j Temme.eee valley Authority - James Oppeld, Aeoistant to Director, Public Is.terest Research Group (Bettomal) - John Abbotte (ettif emeber) .

Enviremmental Flemmia8 *

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)i ashort lauseatees - (Counsel) Univoretty and etbat ,

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' '8"**** William Sibb - Oak Ridge Rettamal 1.aboratory Ems York State tapart=ama of Envirsemmatal Commervatips - lauristem Taylor - Nettomal Ceamcil en Radiation Fretectiam and Measuremmate

Thamme Cashmen Mrector, Berene of Redielegical Follaties Centrol y nethental Barr - Assistaat Director for Special Projects, 31vielen of

• ame Tosh State Departammt of Realth - Biomedical and Davironmental Basearch, Baergy teamarca ,

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- Shesweed Devias. Director, Burene of Radiological Enalth and Development Adelaistraties s -

e Seeth Caro 11ae meerd of mealth - Bormard Cohen - University of Pittsburgh ,

8 Stepham terumsalt, Actear Engineer. (emagested by Emyumed Snealy, Director, ,

Divielen of Radielegice! haasth) Richard Wilaan - Barvard Daiversity Peel "** - Freefdent, asalth phraice Sectetyg Fmedme talversity ,

' Ale 6amm Department of Publis Esalth -

• Anderey Osemia, 31 rector 91siates of andaat gsamt Baalth Goeren r W t - Nattamal Academy of Sciamese - 3RIA an==8steeg j, ;

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Celerede Depestammt of Realth - Salversity of a m ..e ambert Stak. Ameistant Directer for naviremanatal Cameur ne.- '

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aarry osump - 1sternatt 1 Atente amersy Aeoney - 1sternational e

i 1 lamistame separtaaet of Commervation - Imatituta of applied eyetems analysie Joint study ereur.

s. Jim Portes. Administrater, 9tviates of made-essa Canting . 'J mi---- - mopertamos of unaaeh - - p antan Delammt, Chief, Secties of ampenesma gemas.1

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• i questime fadustry states interest and other Total

1. Es it advisable to specify a monetary -

equivalent to the

• cost of radiation L' injury in terne of b

• a dollar / man-sea f

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not as a dellar/

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. roamisties 3 6 L 1 11 > -

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No osintem 0 0 0 1 i 7 10 o 8 29

. 1. Should a general

• # value, applicable to any source el ,

radiation espeoure

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thers factore which womid ouggset that , ,

the applicebility should be restricted

• to specific sourcest Conseal value 4 5 1 '3 13 Source related valuse 2 5 0 4 11 No opialen 1 0 3 1 5 7 10 4 8 29 1 3. Ubat factore ehemid 6 be come Mered in l , develspins a dollar / i ase-res valmet (only specific f actors amatissed by the respondents are listed)

, s. dose levele end does rate effects 3 3

b. cost of treatment for radiaties induced health , i effects 2 1 3 6 )

s. amount of life .'

shortenina 1 1 1 3

d. 1eet productivity  ; ,

and earniamo 1 1 2 4 **

s. benefits free electricirr 2 2

f. cost of tectanolorv 2 2

g. health costs of other l

methods of generattaa eteetricity 1 1

h. menetic effects 1 3 4

1. esposed population 3 3 6

j. risk perception or

! anxiety factore 1 '1 2 4 l

k. no opinico 2 1 1 2 4

, 4, 8bould societal expenditures currently ende to control other sources of health risk be considered in the development of a sunstary equivalent for the cost of radiation tajuryt i

Yee 3 2 S 10 e lee, but saly for semparissa and set is the .  ;

detevaimation 1 6 1 1 e ha 1 0 1

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• He opinion 2 2 2 . A 7 10 4 8 29 1

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UNITED STATES g *, NUCLEAR REGULATORY COMMIS$10N WASHINGTON, D. C. 20066

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March 8, 1976 MEMORANDUM POR: Tom Rehm

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FROM: Ben Huberman '"1

SUBJECT:

h DOLLAR PER MAH-RDi RULEMAKING - ADDENDUM TO SECY-75-679 (REHM MEMO, FEBRUARY 20, 1976)

Issue 2 of the draft paper does not correctly reflect the PE position.

As indicated in the enclosed, PE was not so much concerned with the appropriateness of " risk perception" as an element of the rulemaking proceeding, but rather with the desirability and usefulness of the Connaission sponsoring a study of this subject through the proposed contract to Mitre.

Thus, I recommend that the pap 2r note that the Mitre contract has not yet been consunanated, and that there is some question as to the l desirability and effectiveness of such a contract in support of the purposes the Conunission had in mind for the rulemaking.

Enclosures:

1. Memo from Huberman to Rehu dtd 1-22-76

2. Memo from Pedersen/Kenneke to Huberman dtd 1-30-76 cc: Peter Strauss l

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CONTACT:

Al Kanneke (OPE) 634-1541 Enclosure "C"

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4 UtstTED STATES p 7 NUCLEAR REGULATORY COMMIS$10N l

• ' WASHl800 TON, D. c. s0006 '

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e,,,e January 22, 1976 I

NOTE TO: Tom Behm 1 i

FRON: BenHuberman/)

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SUBJECT:

PENDING CONTlusCTUAL MATTERS REPORT NO. 7 (REHM MEMO, 1/6/76) ,

I concur, except for Section A. ,

I Even if Mitre did a " good" study, the study would still only represent l a single assessment, and it could not suffice for the many other  ;

constructive inputs likely to be received in the dollar per man-rem rulemaking.

For this reason, I think the Section A proposal would not be a wise ~

investment. -

r cc: Peter Strauss l

C tact:

1 Kenneke (OPE) 634-1548 l

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', Enclosure "C"

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UNITED STATES NUCLEAR REGULATORY COMMISSION AG1 43) gg.ig g 8o0?/93 l

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WASHINGTDN, D. C. 20666 NAllC l f

.e.ee January 30, 1976 -

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MEMORANDUM FOR: Ben Huberman I FROM: Ken Peder Al Kennek p 1

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SUBJECT:

f MEETING ON PROPOSED MITRE CONTRACT 1-27-76 I

As a follow-up to your recent memo to Tom Rehm, we attended a meeting in Bethesda*to discuss the proposed contract to be let on a sole saurce basis  ;

to Mitre Corporation, on the subject of a study of the concept of "public I risk perception". The study would be designed to bring together recent writings and discussions about this subject for use in the rulemaking proceeding on dollar per man-rem.

l In summary, we noted two major concerns: (1) that the schedule for the  !

rulemaking proceeding was such that the contract could not be fulfilled '

in time to provide meaningful input to the proceeding; (2) that the substance of the study was not directly necessary or pertinent to the l proceeding and may be contrary to NRC's interests. Discussion revealed that the proposed contract had not been directly brought to the Commission's attention and the subject of "public risk perception" had been broached'only indirectly in the staff paper on the dollar per man-rem rulemaking (SECY-75-679).

l The outcome of the meeting was that:

1. Procedurally, there appears to be no obstacle to going sole source on the contract.

2. If the Commission wishes to carry out the study the timing concerns, i

while tight, can be resolved.

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3. In order to assure that the Commission clearly understands and approves the substance of the proposed study, the study will be specifically flagged and addressed in the next staff paper on dollars per man-rem coming before the Commission. Until formal Commission approval is secured there will be no final agreement with Mitre.

• Other participante: T. Rehm (EDO), R. Mattson (SD), E. Halman (ADM),

S. Goldberg (OCC), J. Sullivan (PLA), R. Smith (RES) v.,--.... n-n u