ML20202G029
| ML20202G029 | |
| Person / Time | |
|---|---|
| Issue date: | 10/08/1975 |
| From: | Donoghue D NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | |
| References | |
| SECY-75-585, SECY-75-585-R, NUDOCS 9902040241 | |
| Download: ML20202G029 (29) | |
Text
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l( W. i i \$tY 3D UNITED STATES SECY 58 5 October 8, 1975 NUCLEAR REGULATORY COMMISSION l
INFORMATION R'EPORT l
F?r: The Commissioners Thru: Executive Director for Operations
Subject:
PETITION FOR RULE MAKING FILED BY THE NATURAL RESOURCES DEFENSE COUNCIL
Purpose:
To advise the Commission of the filing of the .
petition.
Discussion: Enclosed is a petition for rule making filed by i J. G. Speth, Natural Resources Defense Council, Inc. The petition seeks to amend 10 CFR 20.101 -
to reduce the whole body dose limits for radiation exposure. In accordance with our normal ;
procedures and 10 CFR 2.802 of the Commission's i regulations, a notice of filing of the petition .
will be published in the Federal Register. ..
The Office of Standards Development is now preparing an information paper for the Commistaion which will provide background information concerning the petition, bO, S hot A
' Daniel J. onoghue," Director Office of Administration
Enclosure:
-dr" k;d ,
Patition for Rule Making
Contact:
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Dear Sir:
Enclosed please find five copies of the Natural Resources Defense Council's Pctition to Amend 10 CFR 20.101, Exposure of Individuals to nadiation in Restrictcc
.'ireas, together with copies of the supporting report
" Radiation Standards for Occupational Whole Body Exposure,"
dated September 25, 1975, which we herewith file with the Commission.
Sincerely, 4
- J.G. Speth Enclosures .
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In The Matter Of )
) NRC Docket No. ;
RADIATION PROTECTION STANDARDS ) l FOR CONTROL OF OCCUPATIONAL EXPOSURE ) I l
PETITION TO AMEND 10 CFR 20.101 Exposure of Individuals to Radiation in Restricted Areas The NATURAL RESOURCES DEFENSE COUNCIL, INC., ("NRDC" ) , on its own behalf and on behalf of its members, hereby petitions the Nuclear l
Regulatory Commission ("NRC") to amend its radiati.on protection l
standards as they apply to the maximum permissible whole body dose i
equivalent for occupational exposure as more fully described in l l the report, Radiation Standards for Occupational Whole Body Exposure, l 1 l by Thomas'B. Cochran, Ph.D., and Arthur R. Tamplin, Ph.D., submitted I
harcwith. Thi" amendment would have the same effect measured by l l l the reduction in genetic and somatic radiation injury as would be I l l cchieved by reducing the current maximum permissib2c whole body
. dose equivalent for occupational exposure by a factor of ten for I
l genetic injury and six for somatic injury. This request is filed i
4 pursuant to 5 U.S.C. .
S 553 (c) and 10 CFR S 2.002. ;
l
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Identification of Petitioner Petitioner' NATURAL RESOURCES DEFENSE COUNCIL, INC., ("NRDC" ) ,
l l 10 a non-profit, membership corporation organized under the laws i l of the State of New York. NRDC is a charitable organization exempt
) from taxation under Section. 501(c) (3) of the Internal Revenue Code. !
I NRDC's principal office and place of business is located at 15 Mest i
44th Street, New York, New York. It maintains other offices at i
- 917 15th Street, N.W., Washington,*D.C., and at 664 Hamilton Avenue, l Palo Alto, California. NRDC has a nationwide membership of persons dedicated to the defense and preservation of the human environment and .
the natural resources of the United States. Other persons support NRDC's objectives by financial contributions and personal efforts.
l l The objectives'of NRDC include: !
l l
(a) to maintain and enhance the quality of the human -
l environment; (b) to monitor federal departments and regulatory agencies to ensure that environmental valpes are fully considered in decisionmaking, and, in particular, to ensure that federal statutes designed to protect and enhance the environment are fully and properly implemented; i
l (c) to improve federal agency decisionmaking which affects the environment by commenting, furnishing information, and l
)
- initiating and participating in administrative prococdings;
{
(d)' to select and undertake environmental lawsuits which
, have a potential for establishing widely applicabic precedent
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for.saving, reclaimin or protecting some important aspect '
of our national cndowment, including the health and safety of the public; and (e) to provide a central, national focus for scientists, I lawyers, and educators, and concerned citizens in an effort to make our courts and administrative agencies effective instruments of environmental protection.
In pursuit of its objectives, NRDC has been involved in many, proceedings -involving the Atomic Energy Commission and now the Nuclear'Regu'latory Commission.
Petitioner's Interest in the Proceedine i .
l NRDC's basic interest in the captioned proceeding is twofold:
(1) to protect present an'd future NRDC r. embers, their progeny, and l
the public by ensuring the public is' adequately protected from genetic insults resulting from worker'whole body exposure to radiation, and
~(2) to protect present and future NRDC r.cmbers, their progeny, and tha public where they are on occasien e..: ployed by NRC licensees in restricted areas by ensuring that radiation workers are adequately protected from exposure to whole body radiation, by establishing I adequate,radia' tion standards governing maximum permissible occupa- i I I tional whole body exposure to radiation, i
l Supporting Statement Attached to this Petition is a Report prepared by Thomas D.
l
4 i
Cochran, Ph.D., and' Arthur R. Tamplin, Ph.D., entitled, Radiation
. Standards for. Occupational Whol'c Body Exposure, dated September 25, 1975. This Report and the documents referenced therein provide the principal support for and elaboration of.this Petition.
Proposed Action The NRC regulations governing permissible occupational exposure levels to radiation are set out in,the Code of Federal Regulations at 10 CFR 20.101. At present these 10 CPR 20.101 regulations limit tha whole body dose to 1-1/4 rem por calendar quarter (5 rem / year) ,
except a licensee may permit an individual to receive up to 3 rem /
i
. quarter whole body dose as long as the dose to the whole body, when cdded to-the accumulated occupational dose to the whole body, shall not exceed 5 (N-18) r'em where "N" equals the individual's age in years.
l l The objective of the proposed action is to reduce the genetic risk associated with radiation exposure at the current occupational exposure level by a factor of 10 and reduce the somatic risk by a l factor of 6. To meet this objective it is requested that tua c'trrent regulations be amended as follows: '
l
- i
- 1. For individuals under the ago of M, where M is not less than j '45, the whole body radiation exposure limit shall not exceed 0.5 rcm '
t -
- in any calendar-year and 0.3 rem in any calendar quarter.
- 2. For individuals caual to or greater than M years of ago, a licencoc may permit an individual to leccive up to 3 rem / quarter L
' I whole body dose as long-as the dose to the whole body shall not l
J I
exceed (0. 5 ) (M-18 ) + X (N-M) rcm, where N equals the individua3's j
. 1 cgo in yearn, and X is calculated to reduce the cumulative nomatic ricks by a factor of 6 below the cumulative r.isks associated with j l
exposure at 5 rom / year from age 18. It is proposed that the value ;
of X be calculated using the relative risk model as described more 1/ i fully in the BEIR Report. It is further requested that: '
- 3. The NRC institute hearings to determine the "as low as prac- 1 l
l ticable" extent to which the exposures can be maintained below the l
i proposed new regulations. l Time for Action We belicvc that matters of importance to human health and safety require' prompt action. The matters we raise here are based !
1 on data generally known and available for some time. Allowing a reasonabic period for public comment, we recommend that the standards i
requested be set within six months.
Conclusion j The requested action represents minimum steps which must be l l taken to protect' radiation workers and the public from the dangers
- / National Academy of Sciences, National Research Council, "The j Effects on Populations of Exposure to Low Levels of Ionizing Radiation,"
- Report of the Advisory Committee on the Biological Effects of Ionizing Radiations, November, 1972, p. 171. It is proposed that the plateau 4 region, i.e., the interval following the latest period during which the risk remains elevated, for cancers other than leukemia be taken l as the lifetime of the individual. The relative risk model with i ' the lifetime plateau assumption gives the upper limit estimate of j the risk.
i i i
s . v-r of radiation. 'Purther actions consistent with and in furtherance !
l of the Report submitted herewith, including the adoption of addi- j tional standards and guidelines, should be co:ssidered by the NRC [
i toLassurc'that' workers and the public are provided the full pro- l i
taction to which they are entitled.
Respectfully submitted, W ,\
J. Gustave Speth l
NATURAL RESOURCES DEFENSE COUNCIL, INC' .
917 Fifteenth Street, N.W. ,
Washington, D.C. 20005 ,
(202) 737-5000 l Attorney.for Petitioner Dated: September 26', 1975 1
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CITEO l RADIATION STANDARDS TOR OCCUPATIONAL WIIOLE DODY EXPOSUTC ,
1 i
September 25, 1975 Thomas B. Cochran Arthur R. Tamplin l
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. l
- 4 I. Introduction This Report is written in support of a petition by the Natural Resources Dcfonce Council (NRDC) to the Nuclear Regulatory Commission (NRC) requesting a reduction in the maximum permissible occupational'whole body radiation exposure.
'The procent standards-for occupational exposure are based on still current recommendations.of the National Council on Radiation Protection and Measurements (NCRP) and the Inter-national Commission on Radiological-Protection (ICRP) adopted in 1958 and 1959, respectively. The NRDC petition and this
~
Report were-prompted by consideration of the latest infor-
! mation on the biological effects of. radiation. This infor-mation indicatos that the-bioicgicel effects are greater than was assumed in 1958.and 1959 when the existing standards werc recommended. .
1 l
The latest data have been reviewed by a committee l
l of'the !CRP and by the BEIR Commit' tee of the U.S. National j l
1,2/ l Academy of Sciences (NAS) . The BEIR Committee was prin-i . .
fcipally concerned with the exposure of the general population l
1/ ICRP_ Publication 14, Madicscnsitivity and S?atial Dintri- !
bution _of Doso,: Reports Propared by Two Task Groupn of Commi ttec !
1 of the International Commission on Radiological Protection, l l Pergamon Press, Oxford, 1969. ,
l-l' 2/ -_ NAS-DEIR Report , National Academy of Sciences , The Ef f ec,t s
[ on lopulations of ~ Exncsure to Low Levels of lonizinti-)<adiation. )
l- Report of the Advisory Co...mittee on the Biolo ;ical IM fr cLn of l c Ionizing Radiation ; (DEIR Report) , Ennhingron , D. C., November, 1972.
and, in this regard, indicated that the exintincj cxposure l 3/ ;
standard was' unnecessarily high. The ICRP Committee, while declining to make any recommendations, presented a calculation to demonstrate how the new data on the biological l l
effects of radiation could be used to lower the existing :
1/ !
whole body exposure standards by,a factor of ten. The reduction requested in this Report corresponds closely to this factor of ten in the ICRP Committcc analysis.
In January, 1971, while not recommending an overall .
change, the NCRP recommended that the occupational exposure ,
of pregnant women be limited to one tenth die present exposure 5/
limit. The reduction requested in this Report would also fulfill this UCRP recommendation.
In the following section of this Report, we shall
~
present an analysis of the risk of somatic and genetic injury at the current maximum permissibic exposure limit and comparc this risk with those encountered in other occupations. This analysis will serve to indicate that the exposure limit is too high. In Section III, we shall present our requested modifi-3/ Ibid., p.2.
4/ ICRP - Publication 14, og. cit., Appendix IV.
5/ NCRP Report No.39, Basic Radiation Protection Criteria, National Council on Radiation Protection and Measurement, Washington, D. C., 1971, pp.92-93. .
F
l.s-I< , ~ l i + l i !
L ' cations of the exposure limits and an analysis of the reduced l
- risk associa'ted'with-these new limits. In the final section, !
l L we shall indicate how these requested reductions relate l 1
to the recommendation and suggestions of the ICPJ
!!CRP , and the NAS Committee on the Genetic Ef fects of Atomic Radiation.
?
i II .- Radiation Induced Risk at the Existina Occupational Whole Body Dose Limit The latest and most comprehensive review of the
- biological effects of radiation on man is the NAS's 1972 BEIR Report.
The BEIR Committee reviewed both the somatic and genetic risk associated with exposure to low levels of ionizing
- radiati on. We shall discuss first the somatic and then the acnetic effects..
A. Somatic Effects Table 1 summarizes the BEIR Report estimate of the excess annua 3 cancer and leukemia deaths per million people assuming whole body exposure to 5 rem / year (the ' current occupational l E/. i standard). ,
. l 6/ .NAS-BEIR Report, og. cit., p.170. l l
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I-0 Table 1 Calculation of the execus annual number of cancer deaths for individuals exposed from 20 to 65 years of age ABSOLUTE RISK MODEL RELATIVE RISK MODEL Exposure Conditions Excess Deaths Due to: Excess Deaths Due to All Other All Other Leukemia Cancer Leukemia Cancer 10 6 people: 5 rem /yr. 81 (a) 300 181 (a) 601 (b) 336 (b) 746 (a) 30 year plateau .
(b) lifetime plateau (Plateau region = interval following latest period during which the risk remains estimated).
Source: NAS-BEIR Report, p.170.
The r::sk estimates in Table 1 incorporate the assumption that the million people have an ago and sex distribution identical to that of individuals 20 years and older in the U.S. population (1967 statistics) . These figures do not, represer.c a 20 year old individual's chanco of eventually dying of radiation induced cancer (assuming exposure at the 5 rem / year limit) . This chance can, however, be calculated by using the overall i
mortality rate for individuals over 20 years of ago. This death rate in 1973 was 1500 deathe per 100,000 population.
j llence, -if this rate is divided into the frequency of cancer deaths given in Tab]c 1, the chance of a worker, exponed at
- L
l I
5 rem / year from ago 20, dying from radiation induced cancer '
is calculate'd to be from 1 in 16 to 1 in 40. We believe this level of risk is excessive. !
A means of illustrating the excessiveness of the radiation risk to workers exposed at the maximum permissible dose rate is to compare this ris?. With the fatality rate associated with other occupations. .This comparison is given in Table 2. .
Table 2 Fatality Rate by Occupation
, Occupation Yearly Fatality Rate Radiation Worker - exposed 4 at the current-maximum I permissible dose rate a
. (from Table 1) 1 in 1000 to 1 in 2600 United States (1973) '
l All Industries 1 in 6000 Mining and Quarrying 1 in 900 England and Wales c l l
All Occupations . (males) 1 in 5000 to 1 in 10,000 i a Due to cancer induced by occupational whole body exposure
! (at 5 rem /yr.) only.
l -
b National Safety Council, Accident Pactn, 1974 edition, 1974, I j p.23.
c Decanni al Sirmlenen t f or 1:nal.mr1 .m <1 '. 1. n , 'ter i nI rnr 1 Generi.)*n 1949 .1 % 3. Occunat .i on d .Mor t.:1.1 j ty. ParL TII, ;
Vol.2. 11!!30 London (195 ti) a:. referenci d in ICitP Publical ion l
, , _ _ _ , - . . - . . . ._. .- . ._ _ __ _ . . . _ . ._. ___...__.__._m.-. _ _ _ - . . _
i l
[ 'In making the above comparison, we believe'that i-the upper limit of the. radiation induced risk should be used. -
l LThe BEIR Committee cautioned that its estinato may be too l 7/
~
L. high or:too low. One reason for suggesting that it is !
! l 1
- too low in that the 3incar hypothesis is used as'a basis for-extrapolating from high dosc-high dose rate data to low j dose-low rate situations. -Recent evidence suggests that '
Lthe linear hypothesis may underestimate the effect of low >
dose-low dose rate irradiation. The latest information has :
i- been summarized by Dr. Karl Z. Morgan who concluded:
l Frequently in the literature it is-stated that the lincar hypothesis t l is a very conservativo assumption. l During the past few years, howcVer, l
'many studios have indicated'that this probably is not truc in general and
~
that at low doses and dose ratos somatic damage per rad (and especially that fron n-irradiation) probably is usually greater than would be assumed l on the 1incar hypothesis.8/
Thus, there is little justification for relying on i
the lower estimate of the radiation induced risk and prudent l
health practice would indicate that the upper limit should be used.- When this is done, inspection of Table 2 indicates that l
7/ ' Ibid., p.90.
l 8_/ !! organ', Karl Z., Sugger,ted Reduction of Pernir.cib3c Exposurc !
l to Plutoniu:a' and Other Transuranium Elemento, Journal of A:aerican l Industrial'Hygicnc, August, 1975.
the estimated radiation exposure risk corresponds to that associated w'it uning and quarrying, a risk that is acknowl-cdged to be fo too high. The radiation exposure risk execeds the average occupational risk by six fold. In this report, we are proposing a reduction in the risk of radiation indiced cancer at the maximum allowable whole body exposure by a l
i factor of 6 together with the request that the exposures be kept as far below the proposed now limits as is practicable.
1 In making the above comparison and proposing this reduction, l we do not mean to imply that all radiation workers are exposed to the maximum level of the current standards. We only mean to imply that the current exposure standard is an I
i inappropriato guideline against which to apply the as-low-as-practicable rule.
1 It could be argued that it is not appropriate to set the maximum exposure limit at a level that corresponds to the average occupational fatality rate because the limit applies in practico only to the most exposed individuals.
But it is precisely these most exposed workers about whom we must be concerned, and we see no reason why the nuclear j industry should subject its workers-to an above-average rich,
- certainly not when that risk is comparable to that in the mining and quarrying indurtry. Morcoscr, we believe this l
approach is appropriate because radiat ion workers are ah.o 1
I
J l ,
I
' cubject to normal non-radiological occupational hazards, l cnd hence the average risk in the industry will still be above the average for all occupations even with the adoption of our proposed changes. Thus, it would even be reasonable to argue that the risk of radiation induced cancer should be further reduced. Consequently, we see no justification for a higher risk, particularly since the above estimate of l
\
the cancer and leukemia risk does not include the additional risk associated with radiation induced genetic damage.
l
! B. Genetic Effects j The BEIR Report estimated that the total incidence of all identified serious genetic diseases due to 5 rem per generation to a population of 1 million would be between 300 i 9/
to 7,500 per year at equilibrium. In addition, the BEIR Report estimated that this same exposure at equilibrium !
l would eventually lead to an increase of between 0.5% and i 5% in the ill health of the population.
l The approach for estimating the genetically significant dose (GSD) is to use that exposure accumulated l by age 30. The existing exposure lipit would allow a worker
. exposed at 5 rem / year from age 18 to accumulate a dose of 60 rem by age 30. Hence, baned on the DEIR Report estimates l
l 9/ NAS-BEIn Report, op. cit., p.51.
4-above, if one million workers were exponed from age 18
.at_'the current 5 rem /ycar lid
- betwoon 3,600 and 90,000 identified 'scrious genetic _ di: " and a significant-
' increase of ill-health'would n!.,w up in 'the progeny of thesc workers, assuming an average of 2 children por worker.
. The increased incidence in ill-health would be qquivalent to
~
between 6% and 60% of the incidence in a population of 1 million, e.g., t,he first generation. This genetic risk can befcompared with the somatic risk to the workers themselves.
Thus, an~ individual worker e:: posed at 5 rem / year from 18 to ,
'65 years of. age would incur an additional risk of fatal cancer between 11in.16:and 1 in 40,'and an additional risk of between 1 in -10_ and l' in 300_ that one of his progeny will incur a serious - genetic defect. In. terms of the raw numbers, the
~
somatic and' genetic risks . overlap quantitatively. This simpic-comparison of the somatic and genetic risks associated with t
a single worker's lifetime exposure assumes equal weighting of the hurt or suffering associated with the somatic and genetic
! damage.
The genetic risk in different in that the effect is
, suffered not by the workers but by their offspring and by i
future generations. As a consequence, one can argue that the
=
i.
l . genetic' risk should be given more weight because it is not I _ assumed by the worker but involuntarily by~ their of fspring l ,
and by _ future genera tions. Nevertheless, the biological data L
1 r
1- . _ . . ,
4 1
indicates that the risk of genetic damage is comparable to the leukemin and cancer risk and, therefore,.is also too high 4
regardless of any npecial. weighting that it' deserves.
Again, we.strongly suggest that the upper limit
)i estimate'of the(geneticirisk be used in this comparison.
The BEIR Committoc suggested caution in the use of those ;
estimates and began its Discussion section by stating: ,
.1 A major conccan of - the Subcommittee is the possibic existence of a class !
of radiation-induced genetic damage that has been left out of the estimates.
By relying so heavily on c :perimental data in the. mouse we may have overlooked important effe' cts that are not readily detected in" mice, or.the mouse may not be a prcper laboratory model for the study of man.10/
As if to rcomphas.ize this,.the Coro.ittee concluded this section by stating:
We remind all who may'.use our estimates as a basis for policy decisions that these estimates I are an attempt to take into account only known tangible effects of radiation, and that there may wc11 l be intangible ef fects in addition whose cumulative iy. pact may be l
appreciable, although not novel.11/
i E There is reason to suggest that the BEIR Committee should have implied an cvon more cautious approach to their p / Ibid., p.57.
[1/~ ~iiNd."
l
_ _ . -r... _ . -- - - . .I
i ge-,
l 1
e estimates. In the experiments of Dr. William L. Russell at I
.the Oak Ridge National Laboratory, it was observed that the induced mutation frequency at low dose rates was about 1/3 that observed at high dose rates.- The factor of 1/3 was used by the BEIR Committee._ However, Dr. Mary F. Lyon, et al., have analyzed the Russell data along with additional' data from 12/
- experiments at low dose rates. Their analysis shows that as the dose rate drops below some 0.01 r./ min. , the induced mutation frequency begins to increase. They conclude:
In future estimates of the genetic hazards of environmental radiation, therefore, it would be prudent to increase this last figure to a value above that seen in mice at 0.01 r./ min. ,
~for which the maximum likelihood estimate given by the data considered here is 10 X 10~8.13/ .
The value adopted in the EEIR Report was 2.5 X 10-8 mutations per locus per rem or a factor of 4 lower.
Thus, once again there is little justification for relying on the lower limit estimate and prudent health practices indicate that the upper limit estimate should be employed in establishing radiation protection standards.
The upper estimate of the genetic risk (1/10) is comparable Papworth and Rita J. S. Phillips,
~
12/. Lyon, Mary F., D. G.
" Dose-rate and Mutation Frequency af ter Irradiation of Mouse Spermatogonia," Mature W w Diolony, Vol.233, July 26, 1972,
~
l 'pp.101-304. .
. ] 3}/ ' Jpi<1. , p.10_4. .
9
t .~
i
.. l to the upper limit estimate of the somatic risk of 1/16, and this genetic risk , like thc .comatic risk, is excessive. When somatic risk and genetic risk are combined (on an equal wcicht basis) , the combination suggests that the existing exposure standard is at least 10 times too high. In this Report we are proposing a factor of 10 reduction in the genetic risk and a factor of 6 reduction .in the nomatic rink with the additional request as ' stated previously that the exposures be kept as f ar below the proposed new limits as is practicable.
III. Proposed Action The.NRC regulations governing permissible occupational exposure levels to radiation arc embodied in the Code of Federal Regulations at 10- CFR 21.101. At present those 10 CFR 21.101
, regulations limit the whole body dose to 1-1/4 rem per calendar quarter (5 rem /ycar), except a licensec may permit an individua3 to receive up to 3 rem / quarter whole body dose as long as the dose to the whole body when added to the accumulated occopational dose to the whole body, shall not exceed 5 (N-18) rem where "N" equals the individual's ago in years.
The objective of the proposed action.is to reduce the l genetic risk associated with radiation *cxposure at the current l
. occupational exponure level by a factor of 10 and reduce the i
somatic rink by a factor of 6. To acer t he object'ive relative to-the genetic rinh, it. in proposed t. hat the current regulations
t i
- 1. ,
For individuals under the age of M, where M is not less than 45, the whole body radiation t exposure limit shall not exceed 0.'5 rom in any -
calendar year-and 0.3 rem in any calendar quarter. ;
W J To_ mcct the objective relative to the somatic risk, it j is proposed, in addition to the above, that:
- 2. For individuals equal to or greater than M l l
years of age, a licensee may permit an individual 1 i
'to receive up to 3 rem / quarter whole body dose as long as the dose to the whole body shall not exceed'0.5 (M-18) + X (N-11) ren, ahore N equals the individual's at:c in years, and X is calculated to reduce the cumulative somatic risk by a factor of 6 below the cumulative somatic risk associated with ;
exposure at 5 rem / year from age 18. It is proposed that the value of X be calculated using the relativo risk model as described 14/ l more fully in the DEIR Report.
l_4/ N.'.S-B::IR Repor t , op. cit., p.171. It in proponcd that the plateau region, ,i_. o . , the interval following the latent period during which the risk renains c] crated, for cancern ,
other than leukemin be taken as the jifetino of the individual. ]
The_ relative rish mode) with the lifetime plateau ascamption gives the upper linit estimate of the rich.
~ _ . _ . . _ . . _ _ . _ _ . _ _ _ _ . _ . _ _ _ . . . _ _ _ _ . _ _
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t l- It is further requccted.that:
i-
- 3. The UHC institute hearim.jn to determine I I
the "as' low as practicab2c" cxtent to uhich the exposure can be maintained below'the i
proposed now regulations. l l
l The effect of these proposed changes will be to reduce the genetic lisk from occupational radiation exposure at the limiting value by a factor of 10 to about 1 in 100 and reduce' the risk associated with the induction of fatal cancers to about the same leeci. Again, it should be recognized that the ordinary occupational risks and the risk associated with other than whole body irradiation
~
must be added to these whole body 1adiation risks. Never-
. .theless, the'whole' body radiation risk is still quite large and'therefore, it is essential to maintain'the actual l
exposures.as far belou these proposed new limits as is j I
practir.able. i l
l i
! 'IV. ' Additional Justification l <
i The BEIR Committee of the NAS reviewed the more
~
. l recent data on the biological effects of radiation. They
.were concerned mainly with the exposure of the general public.
'In this respect the Corxnittee concluded that the current !
AL/
Radiation Protection Guido was 1,nnocessarily high, a conc] union
- -- --- ,. ...- _u_ l
' 1 l '
which in'our judgment should be equdlly applicabic to
~
3 occupational. exposure standards.
l 1 A Committee of the-JCRP in 1969 reviewed thi l
same material that formed the basis for the BEIR Repo; and i l
indicated that the somatic effects of radiation were 5 to 6 1 times worse than was estimated previously. The ICRP made )
l no rncommendations relative to the c>:posure standards; l
- i rather, .it stated: i i
l The choice between no change and a partial and tentative revision will ,
depend, so it seems to us, not only !
on a scientific assessment of evidence, !
but also on practical considerations, ;
such as the gencral desircbility of' I stability in the recon.nendations over
- a. period of years. The balance between !
practical considorations and incomplete !
I scientific evidence is a matter for judgement outside 'the Task Group's !
frame of reference. -Nevertheless, l it seemed useful to give an exmaple !
in Appendix IV of ho.i our conclusions l about re.lative tissue sensitivity to l cancer induction by radiation might be used as a basis for setting dose limits :
- for individual tissues and organs and !
perhaps for the whole body.16/ l!
i 16/ ICRP - Publication 14, o?. cit., p.33. .
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l In Appendix IV, the Committcc analysis indicated that, l
when the somatic and genetic effects are combined, the whole :
body exposure limit should be reduced by a factor of 10. Thus, I
the changes proposed here arc in accord with this ICRP Committee analysis. j
\
Both the ICRP and NCRP have, recommended that special consideration should be given to pregnant and fertile females.
In fact, in January, 1971, the NCRP recommended:
During the entire gestation period the maximum permissible dose equivalent to the fetus from occupational exposure of the expectant mother should not exceed 0.5 rem.17/
i The changes proposed in this Report would in effect accomodate this recommendation of the NCRP.
The AEC, while acknowledging the greater sensitivity of the fetus, did not amend the dose limiting sections of the Commission's regulations (10 CPR 20). So far as pregnant or fertile women are concerned, the AEC noted difficulties in sex dicerimination, right-to-work and right-to-privacy as L8/
reasons for not changing the limits. The change. proposed here, since it applies to both men and women below the age of 45 eliminates these difficulties.
l In further justification for not changing the dose i
limits for pregnant and fertile women, the AEC stated in its 17/ NCRP Report 50.39, on. cit., p.92.
18/
.,ne Federal Reni ster , Vol. 4 0, No. 2 ~ Friday , January 3, 1975,
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i i
! Federal Register noticc:
Reduction of the donc limits for all rad.iation workers in order to avoid dinerjminnLion ag.iinnt women does not appear practicable. Such a reduction in the dose limits would cost the nuclear industry large sums of money in the application of design and engineering changes and, in some cases, the employment of additional workers in order to accomplish essential work within the reduced individual dose limits. The latter could even result in a net increase in total man-rems of exposure.
Reduction of the dose limit for all workers would aggravate an existing shortage of available manpower in certain key occupa-tions, e.g., radiographers, wolders, and pipefitters, that may involve relatively high radiation expocuren.19/
While we disagree with the philosophy for setting radiation standards implicit in the reference to the large sums of money it would cost the industry, we note that the changes proposed here do not cause all workers to be limited to 0.5 rem / year.
Furthermore, the 3 rem / quarter limit is retaired for older workers. Hence, the proposed changes should not place a large burden on the industry. For exampic, the AEC stated in the Federal Ronister noticc:
19/ Ibid., o.799. ~
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r- 3 l
4 a.
l l
Data on r=sults of , onnel 1 monitoring report.ca ti- :,c Comm.i: inion pursuant tt :; a n . 4 07 .
10 C1'It Pa r t 20 , for calendar ycnr 1973, indicate that 67,flG2 individuals were monitored, 29,169 received measurable exposures averaging 0.73 rem for the year, and .3,4 25 individuals (31. 8 per- l cent of those receiving measurable exposurcs) had estimated exposures
. in excess of 2 rems.20,/ j If M in the proposed regulations were set at 55 years and X at 3 rem / year, the necessary reduction in cancer fatalities would be achieved. If the work force has the same distribution as the population, then some 16S would be over 55 years old and the above quotation indicates that only 120 are presently exposed above 2 rem /ycar. If M were set at 45 and X at 1.5 ,
i rem / year, the cancer reduction would be achieved, and some 370 of the work force could be expected to be above 45. In this latter case, by limiting the exposure of workers over 45 to ;
0.5 rem for 2 years, these same workers (12% of th.e work force
~
in any one year) could roccive 3.5 tem in the third year. Moreover, since there is good reason to believe that the present exposures are not as low as practicable, the industry should not have great difficulty in conforming to those proposed regulations.
20/ Ibid., p.799.
l l
(
0 .. .-
e .. . :
In conclusion, we note that our proposal for limiting the exposure of younger workers while allowing a higher exposure to older worhorn ic not new. It is, in fact, similar to a 1956 recommendation of the NAS Committee on the Genetic Effects of Atomic Radiation in the DEAR Report:
F) That overy effort be made to i assign to tesks involving higher ra- I diation exposures individuals who, for age or other reasons, are unlikely there-after to have additional offspring. Again it is recognized that such a procedure will introduce complications and difficultics, but this committee is convinced that society should begin to modify its procedures to meet inevitable new' conditions.21/
We submit that this recommendation is even more appropriate today. Its justification on genetic grounds is i l
undiminished while, at the same time, the cancer inducing l 1
l potential of radiation is now recognized to be much greater '
. l and the high radiosensitivity of the developing embryo and fetus is also now recognized. In the presence of an .
cxpanding nuclear industry, thc.cime to implement this I recommendation has arrived. .
l I
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21/ NAS BEAR Report, "ational Academy of Sciences, The Biological Ef fects of Atomic Rndiation , Summary Reports, Report of the Committee on Genetic Effects of Atomic Radiation, Wachington, D. C.,
1956, p.29.
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