ML20202F521

Submits Supplementary Info for dollar/man-rem Rule Making Proceeding & to Discuss Four Questions Raised by Commission in Connection with Consideration of Policy Papers SECY-75-679 & SECY-75-679A

ML20202F521
Person / Time
Issue date:	06/03/1976
From:	Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT
To:
References
SECY-75-679B, SECY-75-679B-R, NUDOCS 9902040083
Download: ML20202F521 (24)

Text

a WnUAL USE ONLY N June 3, 1976 u m as srcres S ECY-75-679B _

e NUCLE AR REGilLATO?Y COMMIS$10N f

F'rs The Commissfcaees From: Robert B. Minogue, Director, Office of Standards Development Thru: E::ecutive Director for Operations /

SubPet: SUPPLEMENTARY INFORMATION FOR THE DOLLAR / MAN-REM RULE MAKING PROCEEDING

Purpose:

To discuss four questions raised by the Commission in connection with its consideration of policy papers SECY-75-679 and .

SECY-75-679A. .

In_trrduction: In the Commission Policy Session of Ar-il 15, 1976, the Commis- '

sion requested the staff to provide:* .

(1) a discussion of alternatives for limiting the scope of the proposed rule making proceeding, (2) a discussion of the alternatives for timing of the restric-tions on scope, (3) further information on risk' perception and how such informa-tion can be used, and ,

(4) details of contractual technical support.

Before turning to the specific questions, it is useful to summa- ,

rize the principal issues discussed to date. The schedule for i this rule making proceeding is dependent upon the Commission's decisions on the scope of the rule making and EPA participation in the init,ial public meeting (SECY-75-679). Expansion of the scope beyond values for application to whole body exposure (man-rem) and thyroid exposures (man-thyroid / rem) would lengthen the time required to complete the proceeding. EPA involvement would also require a few months additional time for interagency coordi-nation. The principal schedule options are presented in Enclo-sure A to this paper. (Enclosures "C" and "D" of SECY-75-679

. contain detailed discussions of these alternatives.)  !

Codcct:

R. J. Mattson, SD

• Reference memo from the Secretary to the Executive Director l a

443-6953 for Operations, dated April 30, 1976, cpg ~1s'M96 -

15 L4 'M C jumstf4ALD6ua.. g LE6VLRiscM I4 9Mf?A Vol 6 l

M 4ww-it t Eoct/93

(%L/NLC n m m ,,,,. ,s . . -- .

I 9902040083 760603 l PDR SECY 75-6798 R PDR .

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1 Tha Commissioners The Commission announced, in its decision on Appendix I to 10 CFR Part 50 (RM-50 2), its intention "at the earliest practicable date to conduct a rule making hearing to establish appropriate monetary values for the worth of radiation doses to the popula-tion." The staff has proposed (in SECY-75-679) to conduct a fact-gathering hearing (public meeting) as a first step in imple-menting this intention. The urgency of this action primarily is indicated by the Commission's statement in the Appendix I decision rather than by a need for establishing more appropriate values j than the interim $1,000 values for use in licensing actions. The interim values are presently being used apparently without intro-ducing either limitations on reactor system design or licensing delays. .

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Coestion 1: What are the options for limiting the scope of rule I making? t l

The options for limiting the scope can conveniently be divided I into three kinds of restrictions, as follows:

A. Restrictions on source of exposure

1. light-water reactor effluents i

2. all exposures from light-water reactors 1

3. fuel cycle facility effluents

4. all radioactive effluents

5. all sources of exposure including accidents and occupational exposures B. Restrictions on body orFans to be considered ,

1. whole body and thyroid l

2. other organs where specific biological data are avail- l I

able on health risks, whole body, thyroid, lung, bone, skin, breast, stanach, GI tract C. Restriccions on geographic extent of applicability

1. within 80 kilcmeters (50 miles of a facility)

2. within the continental U.S.  ;

3. world-wide

In deciding which restrictions to apply, there are two kinds of considerations, namely

I. Technical considerations l

a. availability of bioeffects data i

b. availability et health cost data l

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3-II. Procedural considerations

a. manageability of the rule making proceeding

b. time required to complete rule making proceedings

c. staff resource requirements

d. relationships to other on-going Commission actions

e. opportunity for public participation in decision making The alternatives in SECT-75-679 were stated in terms of sources of exposure (A.1, above) because these restrictions contained by implication the other technical limitations on the " cope. That is, the recommendation to restrict the proposed rule making to exposures from light-water reactor effluents implies restrictions on organ doses to be considered (only whole body and thyroid are identified by Appendix I as important population dose' consider- ,

ations); restrictions on dose rate (normal releases less than l

0.5 rem / year and not accidents); and a restriction on geographi-cal extent of applicability (within 50 miles of the facility, the region in which the major portion of the population dose from reactors is delivered). Extension of the scope to other facility effluents would entail four further technical complications beyond

! those inherent in the recommended alternative:

1. Extension to other organs - Whole body and thyroid popula- '

tien exposures predominate for light-water reactor effluents.

The lung, bone, skin, and GI tract' also would have to be considered for other fuel cycle facilities such as fuel fabrication and fuel reprocessing;

2. Possible extension of the geographical limitation - Although l

the' major portion of the population dose from reactor efflu-ents is delivered within 50 miles of the facility this restric-tion may not be valid for fuel reprocessing where the major '

population dose is delivered world-wide from long-lived radionuclides such as tritium, carbon-14 and krypton-85.

Proposed EPA uranium fuel cycle standards and a draft 1AEA l

code of practice both consider world-wide exposures. Given l these precedents, the 50-mile radius restriction would not be valid for reprocessing facilities. This, in turn, intro-  !

duces further technical complications in that the health costs l for a radiation induced hedith effect are apt to vary from country to country. Analysis of this information would mate-l l

rially lengthen the period of completion of this rule making.  !

We estimate the additional time required for this effort to i I

! be two years, primarily because data from other societies would be difficult to obtain.

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Th2 Commissioners i

3. Temporal limitations - The Appendix 1 rule consJders only the 50-year dose commitment. Exposures from other fuel-cycle facilities could require a longer period of consider-ation due to the persistence of the long-lived radionuclides emitted.

4. Implementation models - In order to apply a dollar / man-rem value in the regulation of other fuel-cycle facilities, the staff would have to develop models for predicting the efflu-ents, their dispersion, exposure pathways and dose rates.

World-wide dispersion models are substantially different from those required for light-water reactor effluents within the 50-mile constraint. Development of generic implementation models could take about 2-3 years. Previous experience with Appendix I has shown that the details of implementation are as important as the rule itself in controlling effluents and in managing the case-by-case licensing process.

These are the technical complications entailed in expanding the scope of the dollar / man-rem rule making beyond thyroid and whole body exposures from LWR ef fluents. The original paper (SECY-75-679) detailed the procedural considerations associated with alternative scopes. In particular, two of the points raised in SECY-75-679 should be reemphasized:

1. ALARA design objectives and limiting conditions for operation:

Section IID of Appendix I of 10 CFR Part 50 pertaining to pop-ulation exposures is applied only after the requirements for individual exposures in Sections IIA, B, and C of Appendix I are met. Equivalent ALARA levels for individual exposures have not been formulated for other than light-water-reactors and are not likely to be available within the time frame of interest for this rule making (see SECY-76-ll4).

2. NEPA requirements and the costs to industry: Determination and establishment of a dollar / man-rem value is independent of the cost of control technology. Therefore, it does not l provide a measure of the costs to industry nor of the levels of exposure permitted to individuals or population groups, i

These two factors would have to be considered before a dollar /

man-rem vslue could be applied to facilities other than LWRs.

Application to other classes of facilities, either case-by-case or generically in a regulation, would require the analysis of control technology and its costs, its effec-tiveness, and its availability.

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Question 2: What should be the timing of the scope limitations?

There are four general alternatives as to the timing of the limi-

! tations on the scope of the rule making.

I 1. Defer.any scope limitations to the final decision by the Commission.

2. Defer decision on scope limitations until after initial

-- public hearing (meeting) to solicit public input.

3. Indicate prior to the public hearing (meeting) the Commis-l sion's intent to limit the scope and solicit public comment

via the initial notice of intent to hold the meeting.

l l 4. Limit the scope initially and do not seek public comment on this issue.

The principal considerations are the manageability and timing of the proposed rule making proceeding and the opportunity for pub-lie involvement in the decision making process. Alternatives 1 and 2 provide for maximum public participation but incur the risk of an unmanageable proceeding as discussed in detail in SECY l 679, Enclosure "D". Alternative 4 limits public participation and involvement in decisions regarding the scope. Alternative 3 i permits public comment on tentative limitations. Limitation of l the scope of the rule making prior to a public hearing (meeting) l would aid in managing the~ rule making.

Rscommendatiq1: The staff continues to recommend, as in SECY-75-679, restriction I (Qu ctions 1 & of the scope of the rule making proceeding to the establishment l l 2 concerning of dollar /(whole body) man-rem and dollar / man-thyroid-rem values. I ccop2) These values would be directly applied in connection with the light-water-reactor effluent limitations of Appendix I to 10 CFR l.

Part 50. They could also be considered on a case-by-case basis, where applicable, to other licensing actions.

1 As for the timing of this restriction, the staff recommends that l the Commission's preliminary decision and the reasons for this limitation be set forth in the Notice of Intent, and that public l comment on this limitation be solicited prior to formalization of the scope and procedures for the public meeting.

Question 3: What is risk perception and how does it relate to l this rule making? l I

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Th2 Commissioners Discussion: The purpose of studying risk perception in connection with the dollar / man-rem rule making is to make certain that the proceed-ing accounts for moral, ethical, and human values that the Com-mission indicated should be incorporated in this rule making in addition to purely actuarial considerations. We know of no analytical methodology presently capable of quantifying these factors, save one, and it is an indirect method: analysis of comparative expenditures, that is, the way societal expenditures 1 are presently made in controlling technologies that entail con- I sideration of the prevention of loss-of-life or ill-health.

Although, morally, an identifiable human life is of inestimable worth, societal expenditures to prevent the statistical loss of an unidentified human life are finite. We have proposed to study (Task IV of Enclosure B) expenditures in transportation safety, cancer research, and pollution control in order to determine whether there is any association between these expenditures, the actual health risks, and the perceived health risks. ,

l Another source of information (Task III of Enclosure B) that will be used as input to a determination of these societal values will be jury awards in liability or compensation cases. These will j provide a measure of societal values (as represented by juries) for ill health, injury, pain, and suffering. However, such awards will be only of limited applicability to the estimation of the monetary value of population radiation exposure reductions since ,

they are awarded ex post facto in compensation for a loss already '

incurred, rather than for the prevention of such a loss.

The adaptation of this information requires knowledge of whether current societal expenditures for risk prevention are associated with the risk as perceived by the public or with the magnitude of the real risk. If there is no association with perceived risks and control expenditures in these other areas, it is clearly pos-sible to exclude such considerations from expenditures for control of radioactive material emissions. Conversely, if an association is found between these expenditures and perceived rather than real risks, then we would need a basis for showing that the regulatory process should be structured according to real risks rather than l subjectively perceived risks, or we would need to restructure l the process according to perceptions of risk.

Neglect of.the phenomena of perception of health risks will prob-ably lead to unanswered public criticism of the dollar / man-rem based primarily on purely actuarial considerations. People will conceivably reject such a value because their understanding of other hazards, such as traffic fatalities, is more direct than i

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1 their understanding of chronic radiation injury. This phenomenon j has been shown in the case of apprehension regarding cancer as j opposed to other forms of death (over one-half of all projected-l radiation health effects are attributed to cancer co that this l perception effect is apt to be significant for' radiation exposure).

! Recommendation: That risk perception be studied as a possible factor that.influ-(Qusation 3: ences public expenditures for risk reduction and that the ques-

' Rick perception). tion of excluding such considerations from the rule making be deferred until completion of such studies and solicitation of information via the public meeting.

l Question 4: What are the technical contractual support. activities L related to this rule making?

l Enclosure B to this paper provides a detailed description of the contractual technical support requirements for the alternative-recommended by the staff to limit the scope of the rule making l proceeding to whole body and thyroid doses.

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Coordination: This paper has been concurred in by .the Office of Executive Legal Director. The staff recommendation on limitation of scope has been concurred in by NRR, NMSS, RES, IE, SD, and OELD as l

originally stated in SECY-75-679. OPE has no comment, modifica-L tion indicated in OGC comments (Enclosure "C") was made.

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&tf wp-Robert B. Minogue, Director Office of Standards Development Enclosures (3)

A - Schedule Options  ;

B - Technical Support L

Requirements C - OGC Comments DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations

! Secretariat i

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l ENCLOSURE A i

Four specific schedule options are shown on the next page. They l correspond to the following general options:

1 (1) Staff recommendation for optimum procedural control of the pro- '

I l ceeding to produce directly applicable results considering all related factors in a reasonable time period using best qualified and experienced contractors..

l (2) Revision of option (1) to provide the shortest feasible schedule.

i l (3) Revision of option (2) to provide shortest schedule for giving l consideration to all fuel cycle effluents.

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l (4) Revision of option (3) if an environmental impact statement is required for application to fuc1 cycle facilities other. than LWRs.

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i Enclosure A I

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l Technical Assistance Requirements for the Determination of the Monetary Worth of the Value of Reductions in Population Radiation Exposures (Dollar / man-rem)

December 1975

, Revised March 1976 Revised May 1976 l

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' Division of Siting, Health, and Safeguards Standards Office of Standards Development U.S. Nuclear Regulatory Commission Washington, D.C. 20535 Enclosure B I

..,.~._-.-._-._.---..g.. .-. .-. . . . - . - - - - . . . - . . - . - -.. - - - - ..

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1. Introduction and Summary on April 30, 1975, the Nu". lear Regulatory Commission issued-its deci- i

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sion on numerical guides for design objectives and limiting conditions for.

operation to meet the criterion'"as low as reasonably achievable" for radio-active materials in light-water-cooled nuclear power reactor effluents

[ Docket RM 50-2).1 In Section 4, Chapter I, Summary and Statement of Con-siderations of its decision, the Commission stated its intention to conduct, I

at the earliest practicable date, a rule making hearing to establish appra-

.priate monetary values for the worth of reduction of radiation doses to the population.

This document describes the program plan for technical assistance eff6rts, through contractual support outside NRC, to provide information for use by the staff in the rule making proceeding on the determination of i

tha y r priate monetary value. There are four component tasks which will be undertaken by outside contractors in this connection:

Task I. Evaluation of alternatives to the dollar / man-rem  ;

approach for evaluating the cost-effectiveness of radioactive

' effluent treatment systems.

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Task II. . Determination of the economic costs associated with l radiation-induced disease, i.

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'1 As published in the FEDERAL REG 14ER of May 5, 1975 (40 FR 19439).

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i Enclosure B

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Task III. Development of a Socio-economic Model for Expenditures l to Prevent.a Statistical Loss-of-Life.

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Task IV. Study of the Relationships between Risk Perception and Societal Expenditures for Risk Reduction.

l These tasks represent technical assistance activities to supplement in-house work by the NRC s'taf f. The use of outside contractual support l

l is required in order to provide technical expertise in the social, economic, l

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End biomedical sciences which are not adequately represented on the NRC staff and to perform a detailed analysis of the costs associated with radiation-induced injury.. The projected resource requirements for this project are summarized -in Table 1.

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Enclosure B l l

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\ 1 I l Table 1. Projected Resource Allocations l for Dollar / Man-rem Rulemaking Proceeding i Praction of l 'In-house __ time i Project Officer - Senior Environmental Health Physicist 100%

! Environmental Economist 20%

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i Chief, Environmental Standards Branch 10%

Assistant Director, Siting and Health-Standards 5%

Director, Division of Siting, Health l and Safeguards Standards 5%

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-Consultants 10%

Total 1.5 man-years l

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! -Contractual Support $1,000 l

Task I. Evaluation of Alternatives (9 mo.) 50 Tasi 11. Estimation of Cost of Radiation Injury (12 mo.) 150 l

Task III. Model of Life-Saving Expenditures (12 mo.) 90 l

!. Ta s k I'.'. Risk Perception (9 mo.) 75 l Total $ 365 i

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Enclosure B l

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I j II. Proposed Approach The determination and application of a monetary value for the worth i of reductions in population radiation exposures require the answering of I four primary questions:

l 1. Are there methods other than those requiring a specific dollar /

man-rem value for comparing the costs and benefits of radioactive effluent treatment systems?

2. What is the socioeconomic cost of the potential radiation-induced l- injuries that might occur in populations exposed to nuclear facility effluents?

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3. What.is the appropriate expenditure to reduce the postulated l risk to human health from irradiation of the general population?

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! ... What is the impact of a spet.ific dollar / man-rem value upon the cost and availability of nuclear power and on the dose received by individuals and the general population?

l i-l The first three questions are related to the determination of the dollar /

l man-rem value and the evaluation of alternate methods of balancing the ,

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!- costs and benefits associated with reductions in population radiation doses.

Question 4 relates to the value and impact of applying a specific dollar /

F man-rem value (or an equivalent method of performing cost-benefit compari-sons) in the regulation of specific types of facilites. This last issue

-is not inherent in the determination of the dollar / man-rem value; rather, i

Enclosure B l

l it arises from the application of such a value in regulatory actions and i the need to assess the impact of such application. This impact assessment l l

is required by NRC pursuant to the National Environmental Policy Act of 1969 (NEPA) for case-by-case facility licensing actions and for major rule makings significantly affecting the quality of the environment. Current  :

1 NRC policy also requires a value-impact analysis of all proposed changes in regulatory requirements. The analysis of the impact of a specific dollar / l man-rem value will be performed ir.-house following the determination of a value. If the value is applied only to LWRs, then an addcndum to WASH-1258, the environmental impact statement for Appendix I, likely will suffice.

l l The first question concerns the examination of alternatives to setting a dollar value on population dose. This examination is required by the NRC policy to consider the value <and impact of alternative regulatory actions and will be the function of Task I, Question 2 requires an estimate of the economic costs of radiation injury. Task II is devoted to the statistical analysis of the probability of incurring ill health or injury resulting from radiation exposures, the prognosis of such injury, and the associated money costs of the injury (for example treatment costs, lost productivity, and decreased consumption). This is primarily an actuarial study to define the cost of radiation injury. Although Task II will define the social cost of low-Icvel radiation exposure, it does not define the expenditure to prevent or reduce these costs. In particular, it raises the issues of whether the prevention costs should be equal to or greater than the cost of postulated injury? Or, in view of the uncertainty of the dose-effect i

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relationships at low-dose levels, should the expenditures be less than the l

l postulated costs?

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Tasks III and IV_will provide information needed to answer question 3 concerning appropriate value-for preventing a statistical loss-of-life or l

[ life shortening. Task III will provide an analysis of past life-saving or injury prevention expenditures and will study the validity of models which attempt to quantify societal value parameters. Task IV will analyze life value estimates and current risk reduction expenditares in the U.S.

in areas such as cancer research, transportation safety, and pollution control to determine whether these expenditures are related to actual or 1

i perceived-risk levels. The results from Task IV will provide a measure l

l ' of whether risk perception is a factor in the societal allocation of expenditures for safety and reduction of health risks. If perceived i

! riska are not related to such resource allocations for non-nuclear hazards, i then a reasonable case can be made for their omission from a cost-benefit balancing for radiation exposure reduction. Taken together, Task I, II, III, and IV will provide the necessary'information for the NRC to develop l

the monetary value of the worth of radiation exposure reductions.

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III. Task Descriptions l 1

l Task I

Title:

Assessment of alternatives to the dollar / man-rem approach for evalu- l l

ating the cost-effectiveness of radioactive effluent treatment systems.

l Study Objective: To identify and evaluate methods which do not require the determination of a monetary value for the cost of radiation-induced ill health for evaluating the cost-effectiveness of radioactive effluent control systems.

Required Completion Time: 9 months.

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Estimated Level-of-Effort: 1 man-year. l Suggested Task Group Composition: Economist and engineer with background in cost-benefit or cost-effectiveness studies.

Form of Output: Research report.

Desired output: 1. Identification of alternative methods and analyses of the practicability of employing each method to case-by-case licensing actions.

2. Determination of data requirements, assumptions, and models required for the implementation of the alternatives and estimates of the cost of obtaining these data.

3. Examples of the application of the most promising alternatives to actual systems. Example calculations may be based upon Enclosure B

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the systems presented in WASH-1258, the Appendix I final environmental I etatement, and the equipment costs are to be derived from methods pro-i vided in NRC regulatory guides (to be furnished by NRC).

Task II  !

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Title:

Determination of the economic costs associated with radiation-induced disease.

Study Objective: To define a monetary equivalent to the costs associated j vith potential radiation-induced somatic and genetic effects in man from low-level irradiation of population groups from nuclear facility effluents.

Required Completion Time: 12 months.

Estimated Level-of-Effort: 3 man-years.

Suggested Task Group Composition: Public Health Economist, Radiobiologist, cnd Bio-statistician.

Form Of Output: Research report.

I Desired Output: 1. Monetary costs (in 1975 dollars) per unit of popula-tion dose (in dollars / man-rem for whole body irradiation and dollars / man-organ-rem for irradiation of specific organs) as a function of the organ l irradiated and the age and sex of the individual based upon:

(a) Existing age-specific risk estimates for irradiation of the total body and individual organs (derived fror NAS-NRC BEIR, UNSCEAR,

ICRP and current research studies).

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(b) The monetary costs associated with life-shortening produced by chronic irradiation including: '

(1) consideration of latent periods for tumor induction or manifestation of ill health; (2) the probability of detection of disease, the reported efficacy of treatment methods, the cost of treatmest including hospital length of stay and radio- or chemo-therapy costs; (3) survival times with and without treatment including con-sideration of spontaneous remission; (4) present value of lost earnings based upon age-dependent life-cycle earnings estimates including consideration of monetary equiva-lents for leisure time, and other indirect losses; (S) consideration'of economic impact from loss of productivity l

and decreased consumption; and j t6) normal survival and life expectancy of various age-sex group 2 in the U.S. national population.

Estimated monetary values should be provided for irradiation of the whole body,and the following organs: thyroid gland, lung, GI tract, skin, i

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cnd lense of the eye.

2. The monetary costs (in 1975 dollars) per unit of dose i

for whole body irradiation and specific organ irradiation (dollar / man-rem  !

and dollar / man-organ-rem) for a population having the same ege and sex  ;

distribution as the estimated 1975 U.S. national population based upon the ege-specific risks and economic costs estimated in 1.

Enclosure B l

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3. Monetary costs (in 1975 dollars) per unit of dose (dollars / man-rem) for the genetic effects resulting from irradiation of the l gonads including:

(a) incidence of birth defects, potential for surgical correction cnd costs for correction; (b) hereditary disease induction, resulting life-span shortening end economic costs thereof; (c) stillborn fetuses, spontaneous abortions, and lethal mutation production; (d) consideration of age, fertility, and distribution of births by age of father; and (e) time period required to achieve equilibrium with natural selection.

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4. Comparison of incremental national monetary costs due to man-made irradiation compared to: (1) natura) incidence of individual diseases and (2) estimated incidence of disease from naturally occurring rcdiation sources assuming:

(a) U.S. population distribution; (b) Natural dose rates reported in UNSCEAR and EPA documents; and (c) Population dose distributions to be supplied by the NRC staff for light-water-reactor effluents.

Comments: In performing the evaluation, it may be assumed that the prog-nosis of a radiation-induced disease is the same as currently exists for the same disease, unless there are human exposure data which show otherwise.

Er. closure B i

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Methods of treatment if'a particular effect may be assumed to be employed in the same proportions and at the same cost as the U.S. national data would indicate.

Task III  !

Title:

Development of a socio-economic model of life-saving expenditures.

Study Objective:. Develop a model for estimating public expenditures for life-saving or risk reduction.

, Required Completion Time: 12 months.

Estimated Level-of-Effort: 2 man-years.

Sugreeted Task Group Composition: Economist, Sociologist or Anthropolo-gist, and a Psychologist.

Form of Output: Research Report.

Desir;ad Outputs: 1. A critical review of existing studies of societal risk acceptance including social and psychological factors.

2. An analysis of current economic models for the monetary value of a human life.

3. ~ Synthesis of a model incorporating the results of 1 and_2 which can be used to determine public expenditures for life-

. shortening for a statistical unidentified individual.

4. Estimation of the uncert ainty of the model. ,

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Enclosure B I

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l Task IV

Title:

Study of the relationships between risk perception and societal  ;

l expenditures for risk reduction.

l Study Objective: (1) To determine and evaluate the principal factors involved in the public perception of risks; (2) to compare public percep-

tions.of the risks of nuclear and nonnuclear electric power plants with other risks to which the public is commonly exposed; and (3) to determine the association between the above factors and current levels of expen-l l

ditures to control these risks.

l Required Completion Time: 9 months.

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i Estimated Level-of-Ef fort: 1.5 man-years.

l l Suggested Task Group Composition: Economist and political scientist /

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' 1 histarian.

! Form c.f Output: Research report. l I

i l Desired Output: 1. Examination of the actual and perceived risks in l

l terms of the probability, impact on health, and discounted monetary or property loss for voluntary (e.g., public transportation and hazardous occupations) and involuntary (e.g., nuclear and nonnuclear power plant siting) risks. l

2. Determine what association exists between current  !

levels of expenditure for risk' reduction and the real and perceived risks.

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Enclosure B

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3. Determine the factors which affect public percep-tion of risk and whether these factors have been incorporated either unknowingly in the cognitive decision process or knowingly and on the record of official decision processes in other technologies to determine the levels of expenditures to control risks to which the public is exposed.

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l Enclosure B

r o

O je 4 US6ITED STATES NUCLEAR REGULATORY COMMISSION 3 'a y

je wAaHt000T088. D. C. 20066 4, co . . * <[ May 20, 1976 MEMORANDUM FOR: Thomas A. Rehm, Assistant to the Executive Director for Operations /

FROM: Peter L. Strauss, General Counsel

SUBJECT:

SUPPLEMENTARY INFORMATION FOR THE DOLLAR /

MAN-REM RULE MAKING PROCEEDING The discussion of risk perception appears to omit a major possibility. The last sentence of the third paragraph on page 6 notes that if an association is found between expen-ditures and perceived rather than real risks "we would need a basis for showing that the regulatory process should be structured according to real risks rather than subjectively perceived risks." Isn't another possibility restructuring the regulatory process according to perceived risk? If we know at the outset that is impossible, why study risk per-ception at all? To make clear what is apparently at stake here, I would add a phrase at the end of the sentence in question: "

...,or we would need to restructure the process according to perceptions of risk."

Contact:

Steve Goldberg 492-8156 l

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Enclosure C